EPA 260-R-09-006
                        October 2009
Toxic Chemical Release
Inventory Reporting Forms
and Instructions
Revised 2009 Version
Section 313
of the Emergency Planning and
Community Right-to-Know Act
(Title III of the Superfund Amendments
and Reauthorization Act of 1986)

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                        Important Information for Reporting Year 2009
                                    Table of Contents
New Information for Reporting Year 2009	v
        Other Important Information for RY 2009	vi
        TRI-ME2009	vii
        Web Sites and Points of Contact for Assistance	viii
A.      General Information	1
A.I     Who Must Report	1
A.2     How to Submit Forms	1
        A.2.a.   How to Submit Form R(s) and/or Form A(s) to EPA via the Internet (EPA's Central
        Data Exchange (CDX))	1
        A.2.b   How to Submit Paper Form R(s) and/or Form A(s)	2
A.3     Trade Secret Claims	3
A.4     Recordkeeping	3
A.5     How to Revise or Withdraw TRI Data	4
A.6     When the Report Must Be Submitted	6
A.7     How to Obtain the TRI Reporting Forms	6
B.      How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A.... 7
B.I     Full-Time Employee Determination	7
B.2     Primary NAICS Code Determination	7
        B.2.a.   Auxiliary Facilities	10
        B.2.b.   Multi-establishment Facilities	10
        B.2.c.   Property Owners	11
B.3     Activity Determination	11
        B.3.a.   Definitions of Manufacture, Process, and Otherwise Use	11
        B.3.b.   Persistent Bioaccumulative Toxic (PBT)	14
        B.3.c.   Activity Exemptions	15
B.4     Threshold Determinations	21
        B.4.a.   How to Determine if Your Facility Has Exceeded Thresholds	22
        B.4.b.   Threshold Determinations for On-Site Reuse Operations	23
        B.4.c.   Threshold Determinations for Ammonia	24
        B.4.d.   Threshold Determinations for Chemical Categories	24
        B.4.e    Threshold Determination for Persistent Bioaccumulative Toxic (PBT) Chemicals	25
        B.4.f   Mixtures and Other Trade Name Products	25
B.5     Release and Other Waste Management Determinations for Metals, Metal Category Compounds,
        and Nitrate Compounds	26
C.      Instructions for Completing TRI Form R	32
Parti.   Facility Identification Information	32
        Section 1.   Reporting Year	32
        Section 2.   Trade Secret Information	32
        Section 3.   Certification	32
        Section 4.   Facility Identification	32
        Section 5.   Parent Company Information	34
Part II.  Chemical Specific Information	35
        Section 1.   EPCRA Section 313  Chemical Identity	35
        Section 2.    Mixture Component Identity	36
        Section 3.    Activities and Uses of the EPCRA Section 313 Chemical at the Facility	36
        Section 4.    Maximum Amount of the EPCRA Section 313 Chemical On-site at Any Time
        during the Calendar Year	38
        Section 5.    Quantity of the EPCRA Section 313 Chemical Entering Each Environmental
                    Medium On-site	39
        Section 6.    Transfers of the EPCRA Section 313 Chemical in Wastes to Off-Site Locations.. 46

                   Toxics Release Inventory Reporting Forms and Instructions                     i

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        Section 7.  On-Site Waste Treatment, Energy Recovery, and Recycling Methods	55
        Section 8.  Source Reduction and Recycling Activities	62
D. Instructions for Completing Form R Schedule 1 (Dioxin and Dioxin-like Compounds)	74
D.I     What is the Form R Schedule 1?	74
D.2     Who is required to file a Form R Schedule 1?	74
D.3     What information is reported on the Form R Schedule 1?	74
E.      Facility Eligibility Determination for Alternate Threshold and for Reporting on EPA Form
        A	77
E.I     Alternate Threshold	77
E.2     What is the Form A Certification Statement?	77
E.3     What Is the Annual Reportable Amount?	77
E.4     Recordkeeping	78
E.5     Multi establishment Facilities	78
E.6     Trade Secrets	78
E.7     Metals and Metal Category Compounds	78
F.      Instructions for Completing EPA Form A	80
Parti.    Facility Identification Information	80
        Section 1.   Reporting Year	80
        Section 2.   Trade Secret Information	80
        Section 3.   Certification	80
        Section 4.   Facility Identification	80
        Section 5.   Parent Company Information	82
Part II.  Chemical Identification	83
        Section 1.   Toxic Chemical Identity	83
        Section 2.   Mixture Component Identity	84
Index   	85
                   Toxics Release Inventory Reporting Forms and Instructions

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                        Important Information for Reporting Year 2009
Figures

Figure 1. EPCRA Section 313 Reporting Decision Diagram	9
Figure 2A. EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet	28
Figure 2B. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 100 Pound
Thresholds	29
Figure 2C. EPCRA Section 313 Reporting Threshold Worksheet for PBT Chemicals with 10 Pound
Thresholds	30
Figure 2D. EPCRA Section 313 Reporting Threshold Worksheet for Dioxin and Dioxin-Like Compounds
Chemical Category	31
Figure 3. Reporting EPCRA Section 313 Chemicals	38
Figure 4. Hypothetical Section6.2 Completed for Two Off-Site Locations	56
Figure 5. Hypothetical SectionTA	60

Tables

Table I     NAICS Codes	1-1
Table II    EPCRA Section 313 Chemical List (including chemical categories)
           for Reporting Year 2009	II-l
Table III   State Abbreviations	III-l
Table IV   Federal Information Processing Standards (FIPS) Codes	IV-1

Appendices

Appendix A Federal Facility Reporting Information	A-l
Appendix B Reporting Codes for EPA Form R and Instructions for Reporting Metals	B-l
Appendix C Facility Data Profiles and Common Errors in Completing Form R Reports and Form A
            Certification Statements	C-l
Appendix D Supplier Notification Requirements	D-l
Appendix E TRI State Contacts	E-l
Appendix F TRI Regional Contacts	F-l
Appendix G Other Relevant Section 313 Materials	  G-l
Appendix H Guidance Documents	H-l
Appendix I Questions and Answers Regarding Facility Identification Information	1-1
                  Toxics Release Inventory Reporting Forms and Instructions                    iii

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iv              Toxics Release Inventory Reporting Forms and Instructions

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                         Important Information for Reporting Year 2009
New Information for Reporting Year 2009


•   Please note that this 2009 version of the Toxics Release Inventory (TRI) Reporting Forms and Instructions
    document supersedes previous versions of the document.

•   If you are submitting your Form R and/or Form A via TRI-MEweb, the facility's registered certifying
    official must electronically sign the submission before it can be entered into the TRI database. Uncertified
    electronic submissions will not be accepted, will prevent the submission from being processed, and will
    result in a Notice of Significant Error (NOSE) if they remain uncertified after the July 1st reporting deadline.
    A facility must respond to a Notice of Significant Error within 21 days of receipt.  Failure to respond within
    the initial 21 day requirement could result in the issuance of a Notice of Noncompliance (NON). A Notice
    of Noncompliance is not included in a Facility Data Profile (FDP) and is mailed separately.

•   This is a reminder that the TRI program is no longer supporting the desktop version of TRI-ME. EPA
    will accept only TRI-MEweb or paper submissions for RY 2009. We encourage you to file reports
    for RY 2009 using the TRI-MEweb application.
           If you need to revise  prior or current year data (RY2005-RY2009), we encourage you to
           submit revisions using the TRI-MEweb application.  This will give you quicker access to
           your facility data profile.
       •   If you need to revise  forms prior to RY2004, EPA will accept revisions on magnetic media
           (e.g., CD, 3.5" disks) using the TRI-ME software or on paper forms.
           For states not on the state data exchange, TRI-MEweb allows facilities to generate disk/CD
           submissions for their state.  However, please note, that submissions generated of such media
           type using TRI-MEweb will not be accepted by EPA.

•   TRI-MEweb will be available to all reporting facilities in RY 2009, including first-time filers. TRI-MEweb
    is a web-based  version of the popular TRI-Made Easy (TRI-ME)  reporting software.  Facility  Technical
    Contacts will  be emailed an access key by February, 2010. The facility access key is used to  load your
    facility data if you have reported in prior years using TRI-ME software. Please note that, if you are using
    TRI-MEweb for the first time, certifying officials must register for the application at https://cdx.epa.gov.
    This  registration requires the printing, completion, and mailing of an electronic signature agreement.
    Please allow adequate time for the mailing and processing of this form, which is estimated to take a
    minimum of five (5) business days.

    TRI-MEweb can be accessed  anywhere you have a connection to the Internet. Unlike the PC-based TRI-ME
    software, TRI-MEweb requires no downloads or software installs. You no longer have to  contact your
    "system administrator" to get rights to install the software because it's on the Web!

    TRI-MEweb is similar to its predecessor TRI-ME CD/desktop in that it assists you in preparing your forms,
    but TRI-MEweb  offers so much more. TRI-MEweb is not only an interactive, intelligent, user-friendly
    reporting application; it also provides many new features:

    •  Enhanced Data Quality  and Validation           •   Electronic withdrawals/revisions
       assistance                                      •   Third Party Load
    •  Quick Lists                                     •   Multi-establishment reporting
    •  Enhanced Section 8 Calculator                    •   First-time filer reporting
    •  Prior Year revision capability
    •  Trend Analysis Reports

    To learn more about this new solution to TRI reporting, please visit http://www.epa.gov/tri.
                   Toxics Release Inventory Reporting Forms and Instructions

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•   EPA is placing a renewed emphasis on data quality in TRI reports.  Specifically, the Agency has found that
    many facilities report inaccurate parent companies and/or DUNS numbers in Sections 4 and 5 of the TRI
    reporting forms. EPA asks all facilities to verify the accuracy of facility and parent company information
    (e.g., Dun and Bradstreet number, parent company name). Some tips for reporting accurate information
    follow, and related questions and answers are provided in Appendix I.
           A. To verify the accuracy of your facility and parent company Dun and Bradstreet number
           and name, as required in Section 5 of both Form R and Form A, go to
           https://www.dnb.com/product/dlw/form cc4.htm or call 1-888-814-1435 to verify your
           information. Callers to the toll free phone number should understand that the Dun and
           Bradstreet support representatives will need to verify that callers requesting the DUNS
           number are an agent of the business. Dun and Bradstreet recommends knowing basic
           information such as when the business originated, officer names, and the name, address, and
           phone number for the facility.

           B. Facilities reporting to TRI should also make sure they are providing the parent company
           name and Dun and Bradstreet number of the parent company as of December 31st of the
           reporting year.

•   EPA is also looking at using quick lists to verify the names of publicly owned treatment works
    (POTW) and off-site location RCRA ID's in Form R Part II Section 6.1. B and 6.2. These quick lists
    will contain accurate facility location data that is registered and maintained by EPA's Federal
    Registry System.


Other Important Information for RY 2009


    •   Early Data Release of 2009 TRI Reports. EPA has adopted a new strategy to provide the public
        with quicker access to the Toxics Release Inventory (TRI) data.  The facility locator tool
        (http://www.epa.gov/tri-efdr/) provides early access to the individual forms submitted by
        regulated facilities. The annual TRI National Analysis (Public Data Release) for RY 2008, which
        includes  summary data, analyses, and trends, will be released by the spring of 2010.

    •   EPA's Audit Policy. If you discover your facility is or may have been in violation of Section 313
        of EPCRA (TRI Reporting), please refer to EPA's Policy entitled, "Incentives for Self-Policing:
        Discovery, Disclosure, Correction, and Prevention of Violations" (Audit Policy), 65 FR 19618,
        April 11, 2000. You may qualify for having all gravity based penalties waived if your facility
        meets all nine (9) conditions of the Audit Policy. For more information on EPA's Audit Policy,
        see the Agency's web site http://www.epa.gov/compliance/incentives/auditing/auditpolicy.html

    •   EPA's Small Business Compliance Policy. If you have 100 or fewer employees and discover
        that your facility is or may have been in violation of Section 313 of EPCRA (TRI Reporting),
        please refer to EPA's Small Business Compliance Policy. EPA  will eliminate or significantly
        reduce penalties for small businesses that meet the conditions of the Policy, including voluntarily
        discovering violations and promptly disclosing and correcting them. This Policy implements
        Section 223 of the Small Business Regulatory Enforcement Fairness Act (SBREFA) of 1996. For
        more information, see the Agency's  web site
        http://www.epa.gov/compliance/incentives/smallbusiness/index.html.
vi                 Toxics Release Inventory Reporting Forms and Instructions

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                         Important Information for Reporting Year 2009
TRI-MEweb 2009 Application


The TRI-MEweb 2009 application helps facilities in determining and completing their Emergency
Planning and Community Right-to-Know (EPCRA) Section 313 and Pollution Prevention Act (PPA)
Section 6607 obligations. TRI-MEweb is an interactive, intelligent, user-friendly web-based application
tool that guides facilities through the TRI reporting experience. By leading prospective reporters through
a series of logically ordered questions, TRI-MEweb streamlines the analysis needed to determine if a user
must complete a Form R Report or may complete Form A Certification Statement for a particular
chemical. For those facilities required to report, the software provides the user with guidance for each
data element on the reporting forms. Additionally, this web-based application has a one-stop guidance
feature, the TRI Assistance Library that allows users to search the statute, regulations, and many EPCRA
Section 313 guidance documents by key word. For the more experienced reporter, TRI-MEweb allows
direct data entry onto electronic versions of the Form R and Form A Certification Statement. TRI-MEweb
will check the data for common errors and then prepare the forms. All of the information contained in this
RY 2009 Reporting Forms and Instructions book is contained within TRI-MEweb application.

TRI-MEweb allows the user to submit the forms via the Internet through CDX. TRI-MEweb supports
submitting electronically over the Internet using EPA's CDX without mailing any paper to EPA.
Toxics Release Inventory Assistance Library (TRIAL)

TRIAL is a searchable, indexed file that contains the statutes, the regulations, and most of the key
guidance documents a facility is likely to need for TRI reporting. TRIAL is integrated into TRI-MEweb
help menu.

Can I Use TRI-MEweb if I Have My Own TRI Software?

Yes. Some facilities have their own software or use private commercially-available software to assist in
preparing their TRI reports. This "third party software" will need to be designed to produce XML data
files that match EPA's XML schema. These file formats can be found on the TRI home page at
http://www.epa.gov/tri.  You may load these flat files directly into TRI-MEweb and then use TRI-MEweb
to check your forms for data quality errors. You can then also use TRI-MEweb to submit the forms to U.S.
EPA and your state.
                   Toxics Release Inventory Reporting Forms and Instructions                    vii

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Web Sites and Points of Contact for Assistance


Technical Support:
For TRI information and contacts for technical support refer to the "Contact Us" page at
http://www.epa.gov/tri/contacts/contacts.htm

Frequently Asked Questions (FAQ) Service:
TRI users can scan frequently asked questions or submit a new question through the TRI Programs' FAQ
service. Access to the service is available from the "Contact Us" page on the TRI web site:
http://www.epa.gov/tri/contacts/contacts.htm

TRI Reporting Materials:
You can use TRI-MEweb and the TRI Assistance Library to electronically search and read TRI guidance
documents, including this document. The TRI web site contains links and guidance on filling out and
submitting TRI reporting forms: http://www.epa.gov/tri/report/index.htm

TRI Regional Contacts:
EPA Regional Coordinators often work closely with reporting facilities in their area providing training,
outreach, and assistance in completing forms. For a list of TRI Regional Coordinators, see Appendix F.

TRI State Contacts:
EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a list of state-
designated Section 313 contacts, see Appendix E.

Mailing Addresses Associated with TRI Federal Reporting Requirements:
Please see Section A for specific information on what documents must be sent to the Federal government
when submitting Forms R and A, trade secret submissions, and data revision and withdrawal requests.
The addresses where documentation can be sent are provided below. Additional information is provided
in Section A and Appendix E with respect to separate state reporting requirements.

       Forms R and A

     When  mailing  by  U.S.  Postal  Service,   To send  paper  forms  by  certified  mail  or
     send to:                                 overnight mail (i.e. Fed Ex, UPS, etc.), send to:

     TRI Reporting Center                     CGI Federal, Inc
     P.O. Box 10163                          c/o EPA Reporting Center
     Fairfax, VA 22038                        12601 Fair Lakes Circle
                                             Fairfax, VA 22033

      Also send a copy of the report to the state in which the facility is located. "State" also includes: the
      District  of  Columbia, the Commonwealth of Puerto Rico,  Guam,  American  Samoa,  Marshall
      Islands, the U.S. Virgin Islands,  the Commonwealth of the Northern Mariana Islands, and any other
     jurisdiction  and Indian  Country. Refer to  Appendix E  for the appropriate  state  submission
      addresses.

      Facilities located on Indian land should send a copy to the Chief Executive Officer of the applicable
      Indian tribe.  Some tribes  have entered into  a cooperative agreement with states; in this case, report
      submissions should be sent to the entity designated in the cooperative agreement.
viii                Toxics Release Inventory Reporting Forms and Instructions

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                         Important Information for Reporting Year 2009
       Trade Secret Submissions

When mailing by U.S. Postal Service, send  To send trade secret submissions by certified mail
to:                                       or overnight mail (i.e. Fed Ex, UPS, etc.), send to:
          EPCRA Substantiation Packages
          TRI Reporting Center
          P.O. Box 10163
          Fairfax, VA 22038
Attention: EPCRA Substantiation Packages
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
703-227-7644
       TRI Data Revision Requests

When mailing by U.S. Postal Service, send  To send  revision requests  by certified mail  or
to:                                       overnight mail (i.e. Fed Ex, UPS, etc.), send to:
          Attention: TRI Revision Request
          TRI Reporting Center
          P.O. Box 10163
          Fairfax, VA 22038
Attention: TRI Revision Request
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
       Withdrawal Requests

When mailing by U.S. Postal Service, send  To send  revision requests  by certified mail  or
to:                                       overnight mail (i.e. Fed Ex, UPS, etc.), send to:
          Attention: TRI Withdrawal Request
          TRI Reporting Center
          P.O. Box 10163
          Fairfax, VA 22038
Attention: TRI Withdrawal Request
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
                   Toxics Release Inventory Reporting Forms and Instructions
                                        IX

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FORMR
^^ j^ X\r\. Section 313 of the Emergency Planning
Y\ /N, Ripht-to-KnowActof 1Q86 also Ktioi
1 IniTprl ^Tiii"ps
u micu tidies Superfund Amendments and Reauthor
Environmental Protection Agency
WHERE TO SEND COMPLETED FORMS: 1 . TRI Data Processing Center
P.O. Box 1513
Lanham, MD 20703-1513
This
revi
subi
TRI Facilit
I and Community
tm. as litle 111 of the TO xic Chei
izationAct
f ID Number

nical, Category or Generic Name

2. APPROPRIATE STATE OFFICE
(See instructions in Appendix E)
, section only applies if you are Revision (enter up to two code(s)) Withdrawal (enter up to two code(s))
Trilled form otherwise leave blank





IMPORTANT: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1 . REPORTING YEAR


SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
DYes (Answer question 2.2; No (Do not answer 2.2
Attach substantiation forms') n^ ^ Co^;^n i)



T ,, . v^niti-yari Unsanitized
22 Is this copy 	 sanitized | 	 |
(Answer only if "YES" in 2. 1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true and
complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers of this report.
Name and official title of owner/operator or senior management official:

SECTION 4. FACILITY IDENTIFICATION
4.1

Signature:

Date Signed:


TRI Facility ID Number
Facility or Establishment Name Facility or Establishment Name or Mailing Address (If different from street address) |



Street | Mailing Address 1


City/County/State/Zip Code Citv/State/Zic Code 1

4.2
4.3
4.4

4.5
4.6


This report contains information for: An entire 1 1 Part of a
(Important: Check a or b; check c or d if applicable) a- __ facility | 	 | facility c' — —
Technical Contact Name
lelephon

Email Address
Public Contact Name
Telephon

Email Address
NAICS Code (s) Primary
tb« a. b.
d. e.
Dun & Bradstreet a.

Country (Non-US)|

A Federal 1 1 GOCQ
facility d. | 	 |
e Number (include area code) |


e Number (include area code)|


f.

Number (s) (9 digits) b
SECTION 5. PARENT COMPANY INFORMATION
5.1
5.2
Name of Parent Company NA

Parent Company's Dun & Bradstreet Number NA



 EPA Form  9350 -1 (Rev.  10/2009) - Previous editions  are obsolete.

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                                                                                                FRI Facility ID Number
                                   FORMR
         PART II.  TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
                                                                                          Toxic Chemical, Category or Generic Name
 SECTION 1. TOXIC CHEMICAL IDENTITY        (Important: DO NOT complete this section if you completed Section 2 below.)
 1.1
      CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
 1.2
      Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
 1.3
     Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
  SECTION 2. MIXTURE COMPONENT IDENTITY
                                                      (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
      Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)
  SECTION 3.  ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
                  (Important:  Check all that apply.)
3.1   Manufacture the toxic chemical:
                                      3.2   |    Process the toxic chemical:     3.3 |   Otherwise use the toxic chemical:
    a.	 Produce
                     mport
      	  If produce or import
    C.      For on-site use/processing
    d.LJ  For sale/distribution
    e I   I  As a byproduct
    f |   |  As an impurity
a.L
b.[
c.[
d.[
e.F
                                              As a reactant
                                              As a formulation component
                                              As an article component
                                              Repackaging
                                              As an impurity
a. |    |  As a chemical processing aid
b. |    |  As a manufacturing aid
C. |    |  Ancillary or other use
  SECTION 4.1
 4.1
             (Enter two digit code from instruction package.)
  SECTION 5.   QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
                                        A. Total Release   (pounds/year*)
                                          (Enter a range code** or estimate)
                                                                    B. Basis of Estimate
                                                                       (enter code)
                C. % From Stormwater
 5.1
      Fugitive or non-point
      air emissions
                     NA
 5.2
Stack or point
air emissions
                            NA
 5.3
Discharges to receiving streams or
water bodies (enter one name per box)
       Stream or Water Body Name
 5.3.1
 5.3.2
5.3.3
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box
and indicate the Part II, Section 5.3 page number in this box.      I      I  (example: 1,2,3, etc.)
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
                                                                             *For Dioxin or Dioxin-like compounds, report in grams/year.
                                                                   ** Range Codes: A= 1-10 pounds; B= 11-499 pounds; C= 500-999 pounds.

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                                          FORMR
                 PART II.  CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
                                                                                             TRI Facility ID Number
                                                                                      Toxic Chemical, Category or Generic Name
   SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ON SITE (continued)
                                           NA
                                           A. Total Release (pounds/year*) (enter range
                                               code ** or estimate )
 B. Basis of Estimate
  (enter code)	
5.4.1
 Underground Injection onsite
 to Class I Wells
5.4.2
 Underground Injection onsite
 to Class II-V Wells
5.5
Disposal to land onsite
5.5.1A
RCRA Subtitle C landfills
5.5.1B
       Other landfills
5.5.2
 Land treatment/application
 farming	
5.5.3A
RCRA Subtitle C
surface impoundments
5.5.3B
Other surface impoundments
5.5.4  Other disposal
 SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1. A  Total Quantity Transferred to POTWs and Basis of Estimate
6 1 A 1 Total Transfers (pounds/year*)
       (enter range code ** or estimate)
                                                    6.1. A.2   Basis of Estimate
                                                    	(enter code)
 6.1.B
               POTW Name
POTW Address
City
                                          State
                                                           County
             Zip
 6.I.B.
              | POTW Name
POTW Address
City
                                   State
                                                                 County
                                                                                                       Zip
If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
in this box  I     I  and indicate the Part II, Section 6.1 page number in this box  |
                                                                     (example:  1,2,3, etc.)
 SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
 62.	Off-Site EPA Identification Number (RCRA ID No.)
 Off-Site Location Name
Off-Site Address
City
                                   State
                                                          County
Zip
Country
(Non-US
 Is location under control of reporting facility or parent company?
                                                                                           Yes
                                                                                                              No
 EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
                                                                        * For Dioxin or Dioxin-like compounds, report in grams/year
                                                                 ' Range Codes: A=l-10 pounds: B=l-499 pounds; C=500 - 999 pounds.

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    (IMPORTANT: Type or print; read instructions before completing form)
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                                      FORMR
            PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                                                  TRI Facility ID Number
                                                                                Toxic Chemical, Category or Generic Name
   SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (CONTINUED)
   A. Total Transfers (pounds/year*)
       (enter range code**or estimate)
                         B. Basis of Estimate
                            (enter code)
 c. Type of Waste Treatment/Disposal/
   Recycling/Energy Recovery  (enter code)
   1.
                                          1.
                                                                                       1. M
   2.
                                          2.
                                                                                       2. M
   3.
                                          3.
                                                                                       3. M
   4.
                                          4.
                                                                                       4. M
  6 2
            Off-Site EPAIdentificationNumber(RCRAIDNo.)
 Off-Site Location Name
 Off-Site Address
 City
                                 State
County
                                                            Zip
                         Country
                         (Non-US)
 Is location under control of reporting facility or parent company?
                                                                              Yes
                                                                                                 No
 A. Total Transfers  (pounds/year*)
    (enter range code**or estimate)
                         B. Basis of Estimate
                            (enter code)
C. Type of Waste Treatment/Disposal/
   Recycling/Energy Recovery (enter code)
   1.
                                                                                       1. M
   2.
                                         2.
                                                                                       2. M
   3.
                                         3.
                                                                                       3. M
   4.
                                         4.
                                                                                       4. M
  SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
       Not Applicable (N A) -
         Check here if no on-site waste treatment is applied to any
         waste stream containing the toxic chemical or chemical category.
   . General
    Waste Stream
    [enter code]
                  b. Waste Treatment Method(s) Sequence
                      [enter 3- or 4- character code(s)]
        d.  Waste Treatment Efficiency
           [enter 2 character code]
    7 A. la
                  7A.lb
                                                                                                          7A.ld
   7A2a
                  7A.2b
  7A3a
7A.3b  I
                                                                                                          7A.2d
                                                                                                          7A.3d
   7A4a
                  7A.4b
                                                                                                          7A.4d
   7A5a
                  7A.5b
                                                                                                          7A.5d
 If additional pages of Part II, Section 6.2/7 A are attached, indicate the total number of pages in this box
 and indicate the Part II, Section 6.2/7 page number in this box:  | _ |  (example:  l,2,3,etc.)
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
                                                                  *For Dioxin or Dioxin-like compounds, report in grams/year
                                                         "Range Codes: A=l - 10 pounds; B=ll - 499 pounds C= 500-999 pounds.

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   (IMPORTANT: Type or print; read instructions before completing form)
                                                                              Form Approved OMB Number: 2025-0009
                                                                              Approval Expires:  03/31/2011                Page 5 of 5
                                              FORMR
                  PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                                                         TRI Facility ID Number
                                                                                                        Toxic Chemical, Category or Generic Name
    SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
          Not Applicable (NA) -
                       Check here if no on-site energy recovery is applied to any waste
                       stream containing the toxic chemical or chemical category.
       Energy Recovery Methods [enter 3-character code(s)]

                     1    I                   I
    SECTION 1C. ON-SITE RECYCLING PROCESSES
         Not Applicable (NA) -
                     Check here if no on-site recycling is applied to any waste
                     stream containing the toxic chemical or chemical category.
       Recycling Methods [enter 3-character code(s)]
  SECTION 8.  SOURCE REDUCTION AND RECYLING ACTIVITIES
                                              Column A
                                              Prior Year
                                              (pounds/year*)
                                                             Column B
                                                             Current Reporting Year
                                                             (pounds/year*)
Column C
Following Year
(pounds/year*)
Column D
Second Following Year
(pounds/year*)
  8.1
  8.1a
Total on-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
 8.1b
Total other on-site disposal or other
releases
  &lc
Total off-site disposal to Class I
Underground InjectionWells, RCRA
Subtitle C landfills, and other landfills
 8.1d
Total other off-site disposal or other
releases
  8.2
 Quantity used for energy recovery
 onsite
  8.3
Quantity used for energy recovery
offsite
  8.4
Quantity recycled
onsite
  8.5
        Quantity recycled offsite
  8.6
Quantity treated onsite
  8.7
        Quantity treated offsite
  8.8
Quantity released to the environment as a result of remedial actions, catastrophic events,
 or one-time events not associated with production processes (pounds/year)*
  8.9
        Production ratio or activity index
  8.10
Did your facility engage in any source reduction activities for this chemical during the reporting
year? If not, enter "NA" in Section 8.10.1 and answer Section 8.11.
        Source Reduction Activities
             [enter code(s)]
                                                             Methods to Identify Activity (enter codes)
 8.10.1
 8.10.2
                                                                     b.
 8.10.3
                                                                     b.
 8.10.4
                                                                     b.
 8.11
If you wish to submit additional optional information on source reduction, recycling, or pollution
control activities, check "Yes."
                                                                                                                    Yes
EPA Form 9350 -1 (Rev. 10/2009) - Previous editions are obsolete.
                                                                                  *For Dioxin or Dioxin-like compounds, report in grams/year.

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 (IMPORTANT: Type or print; read instructions before completing form)
                                                                     Form Approved OMB Number: 2025-0010
                                                                     Approval Expires: 03/31/2011                 Page 1 o
  United States
  Environmental Protection Agency
                                        TOXICS RELEASE INVENTORY
                                                     FORMA
 WHERE TO SEND COMPLETED FORMS: 1. TRI Data Processing Center
                                          P. O. Box 1513
                                          Lanham, MD 20703-1513
                                          ATTN:  TOXIC CHEMICAL RELEASE INVENTORY
                                                                  2.  APPROPRIATE STATE OFFICE
                                                                     (See instruction in Appendix E)
                              TRI Facility ID Number
  This section only applies if you are revising
  or withdrawing a previously submitted form,
  otherwise leave blank.
                                      Revision (enter up to two code(s)
              Withdrawal (enter up to two code(s)
  IMPORTANT:  See instructions to determine when "Not Applicable (NA)" boxes should be checked.
                                 PART 1.  FACILITY IDENTIFICATION INFORMATION
  SECTION 1.  REPORTING YEAR
  SECTION 2.  TRADE SECRET INFORMATION
2.1
 Are you claiming the toxic chemical identified on page 2 trade secret?
    I Yes  (Answer question 2.2;        I    I No  (Do not answer 2.2;
 	I      Attach substantiation forms)  |	|     Go to Section 3)
                                                                    2.2
Is this copy  |	|    Sanitized    [
      (Answer only if "YES" in 2.1)
                                                                                                             Unsanitized
  SECTION 3. CERTIFICATION   (Important:  Read and sign after completing all form sections.)	
  I hereby certify that to the best of my knowledge and belief, for each toxic chemical listed in the statement, the annual reportable amount as defined in 40 CFR
  372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was manufactured, processed, or otherwise used in an amount not exceeding 1
  million pounds during this reporting year.
 Name and offical title of owner/operator or senior management official:
                                                                       Signature:
                                                                                                         Date Signed:
   SECTION 4. FACILITY IDENTIFICATION
 4.1
                                                    TRI Facility ID Number
 Facility or Establishment Name |
                                                Facility or Establishment Name or Mailing Address (If different from street address) |
 Street
                                                Mailing Address   |
 City/County/State/Zip Code |
                                                City/State/Zip Code |
                                     Country (Non-US)
4.2 This report contains information for: (Important: Check cord if applicable)
                                                                                           DA Federal
                                                                                           facility        d.
                                                                                                            GOCO
4.3
    Technical Contact Name
                                                                                   Telephone Number (include area code)
    Email Address
4.4
    Public Contact Name
                                                                               Telephone Number (include area code)
     Email Address
4.5
NAICS Code (s)
(6 digits)
                            Primary
                         a.
4.7
Dun & Bradstreet
Number (s) (9 digits)
   SECTION 5. PARENT COMPANY INFORMATION
 5.1
     Name of Parent Company
                          NA
 5.2
    Parent Company's Dun & Bradstreet Number
                                         NA
EPA Form 9350 -2 (Rev.  10/2009) - Previous editions are obsolete.

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  (IMPORTANT: Type or print; read instructions before completing form)                                                                   Page	of __
                                                       EPA FORM A
                                    PART II. CHEMICAL IDENTIFICATION          TRIFID
                                 Do not use this form for reporting PBT chemicals including Dioxin and Dioxin-like Compounds*
   SECTION 1. TOXIC CHEMICAL IDENTITY                                                        Report _of _
     i CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
 1.2
      Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
 1.3
      Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
   SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above)
     Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
   SECTION 1. TOXIC CHEMICAL IDENTITY
                                                                                                            Report	of	
     CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
    i Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
      Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
   SECTION 2. MIXTURE COMPONENT IDENTITY  (Important: DO NOT complete this section if you completed Section 1 above)
    . Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
    SECTION 1. TOXIC CHEMICAL IDENTITY                                                   Report	of	
     CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
     Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
     Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
   SECTION 2. MIXTURE COMPONENT IDENTITY  (Important: DO NOT complete this section if you completed Section 1 above.)
    , Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
  SECTION 1. TOXIC CHEMICAL IDENTITY                                                   Report	of	
      CAS Number (Important:  Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
1.1
    , Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
     Generic Chemical Name (Important:  Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
  SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
. .  Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
    i^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^~^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^~
                      *See the TRI Reporting Forms and Instructions Manual for the list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)

EPA Form 9350 -2 (Rev. 10/2009) - Previous editions are obsolete.
                                                                                          (Make additional copies of this page, if needed)

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 (IMPORTANT: Type or print; read instructions before completing form)
                                                                         Form Approved OMB Number: 2025-0007
                                                                         Approval Expires 04/30/2010
Page 1 of 4
FORM R Schedule 1
TRI Facility ID Number

United States
Environmental Protection RART II. CHEMICAL-SPECIFIC IN FORMATION (continued)
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

D. Mass (grams) of Each Compound in the category (1-17)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
5.1 NA
Fugitive or non-
point air emissions

















5.2 NA
Stack or point
air emissions

















5 , Discharges to receiving streams or water bodies
(enter data for one stream or water body per box)
5.3.1

















If additional pages of Section 5.3 are attached, indicate the total number of pages in this bo;
and indicate the Section 5.3 page number in this box (example: 1,2,3, etc.)
5.3.2


















<

5.3.3


















EPA Form 9350-3

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(IMPORTANT: Type or print; read instructions before completing form)
                                                                              Form Approved OMB Number: 2025-0007
                                                                              Approval Expires 04/30/2010
Page 2 of 4
FORM R Schedule 1
TRI Facility ID Number

PART II. CHEMICAL-SPECIFIC IN FORMATION (continued)
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE


C. Mass (grams) of Each Compound in the category (1-17)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Underground Injection
5.4.1 NA
Underground
njection onsite
to Class I Wells

















5.4.2 NA
Underground
Injection onsite
toClassll-V
Wells

















5.5 Disposal to land onsite
5.5.1. A NA
RCRA Subtitle C
andfills

















5.5.1. B NA
Other landfills

















5.5.2 NA
Land treatment/
application farming

















5.5.3A NA
RCRA Subtitle C
surface
impoundments

















5.5.3B NA
Other surface
impoundments

















5.5.4 NA
Other disposal

















EPA Form 9350-3

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intentionally blank.

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-------
(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0007
Approval Expires:04/30/2010
Page 3 of 4
FORM R Schedule 1

TRI Facility ID Number

PART II. CHEMICAL-SPECIFIC INFORMATION (continued)
SECTION
6. TRANSFERS OF DIOXIN AND DIOXIN-LIKE COMPOUNDS IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.A.3 Mass (grams) of Each Compound in the Category (1-17)
1
10


2
11


3
12


4
13


5
14


6
15


7
16


8
17


9


6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2.
1.
9
D. Mass (grams]


2.
9

3.
9

4.
9

6.2.
1.
9

9

9

9
1
10
1
10
1
10
1
10








2
11
2
11
2
11
2
11








3
12
3
12
3
12
3
12

of Each Compound in the Category (1-17)









D. Mass (grams)


2.

3.

4.

1
10
1
10
1
10
1
10








2
11
2
11
2
11
2
11








3
12
3
12
3
12
3
12
4
13
4
13
4
13
4
13








5
14
5
14
5
14
5
14









6
15
6
15
6
15
6
15








7
16
7
16
7
16
7
16








8
17
8
17
8
17
8
17








of Each Compound in the Category (1-17)








If additional pages of Section 5.3 are attached, indicate the tota
and indicate the Section 5.3 page number in this box

4
13
4
13
4
13
4
13








5
14
5
14
5
14
5
14








I number of pages in this box
(example: 1,2,3, etc.)
6
15
6
15
6
15
6
15











7
16
7
16
7
16
7
16








8
17
8
17
8
17
8
17









    EPA Form 9350-3

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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2025-0007
Approval Expires:04/30/2010
Page 4 of 4
FORM R Schedule 1
PART II. CHEMICAL-SPECIFIC INFORMATION (continued)
TRI Facility ID Number


SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES FOR DIOXIN AND DIOXIN-LIKE COMPOUNDS (current vear onlv)

r~
T-
T-
1*
o
§•
T*
o
0)
£
C
•o
c
a
o
.C
u
re
LJJ
•5
ur
re
S
in
VI
re
14-1
c
3
o
o
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
8.1a
Total onsite
disposal to
Class 1
Underground
Injection
Wells,
RCRA Subtitle
C landfills, and
other landfills

















8.1b
Total other
onsite disposal
or other
releases

















8.1c
Total offsite
disposal to
Class 1
Underground
Injection
Wells,
RCRA Subtitle
C landfills, and
other landfills

















8.1d
Total other
offsite disposal
or other
releases

















8.2
Quantity used
for energy
recovery
onsite

















8.3
Quantity used
For energy
recovery
offsite

















8.4
Quantity
recycled
onsite

















8.5
Quantity
recycled
offsite

















8.6
Quantity
treated
onsite

















8.7
Quantity
:reated
offsite

















8.8
Quantity released
o the environment
as a result of
remedial actions,
catastrophic
events, or one-
ime events not
associated with
production
processes

















    EPA Form 9350-3

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                                     General Information
A.    General Information
Reporting  to  the  Toxic  Chemical   Release
Inventory (i.e., Toxics Release Inventory (TRI)) is
required  by  Section  313  of the  Emergency
Planning and  Community  Right  to  Know Act
(EPCRA,  or  Title   III  of  the  Superfund
Amendments  and Reauthorization Act of 1986),
Public Law 99 499. The information contained in
the  Form  R  constitutes  a  "report,"  and  the
submission  of  a  report  to  the  appropriate
authorities constitutes "reporting."

The  Pollution Prevention Act, passed into law in
October,  1990 (Pub. L.  101 508), added  reporting
requirements  to  Form  R. These requirements
affect  all facilities  required to submit  Form R
under  Section 313  of EPCRA.  The data were
required  beginning with reports for calendar year
1991.

Reporting is required to provide the public with
information  on  the releases  and  other  waste
management of EPCRA Section 313 chemicals in
their  communities  and to  provide  EPA  with
release and other waste  management information
to assist  the Agency in determining the need for
future  regulations.  Facilities  must  report  the
quantities of routine and accidental releases, and
releases resulting from catastrophic or other one
time events of EPCRA  Section 313 chemicals, as
well as  the maximum  amount of the  EPCRA
Section 313 chemical on-site during the calendar
year and  the amount contained in wastes managed
on-site or transferred off-site.

A completed  Form R  or Form  A  must be
submitted for each EPCRA Section 313  chemical
manufactured,  processed,  or  otherwise  used  at
each covered facility as described in the  reporting
rules  in  40 CFR Part  372 (originally published
February 16,  1988, in  the Federal Register and
November 30, 1994, in the Federal Register (for
Form A)).

A. 1   Who Must Report

•   Section 313 of EPCRA requires that reports be
    filed  by owners and operators of facilities that
    meet all of the following criteria.
•   The facility has 10 or more full-time employee
    equivalents (i.e.,  a total of 20,000  hours or
    greater; see 40 CFR 372.3); and

•   The facility is included in a North American
    Industry Classification System (NAICS) code
    listed in Table I. NAICS codes found in Table
    I  correspond  to  the   following  Standard
    Industrial Classification (SIC) Codes: SIC 10
    (except 1011,  1081,  and 1094),  12 (except
    1241), 20-39, 4911 (limited to facilities that
    combust coal and/or  oil for the  purpose of
    generating  electricity  for   distribution   in
    commerce), 4931 (limited to  facilities that
    combust coal and/or  oil for the  purpose of
    generating  electricity  for   distribution   in
    commerce), 4939 (limited to  facilities that
    combust coal and/or  oil for the  purpose of
    generating  electricity  for   distribution   in
    commerce),  4953   (limited   to  facilities
    regulated under RCRA Subtitle C, 42 U.S.C.
    Section6921  et seq.), 5169, 5171, and 7389
    (limited to facilities primarily engaged  in
    solvents recovery services on a contract or fee
    basis); and

•   The facility manufactures (defined to include
    importing), processes, or otherwise  uses  any
    EPCRA Section  313 chemical in quantities
    greater than the  established threshold in  the
    course of a calendar year.

Executive Order 13423 extends  these  reporting
requirements  to  federal  facilities,  regardless  of
their SIC or NAICS code.

A. 2   How to Submit Forms

Starting this reporting year, facilities can only use
TRI-MEweb or paper for submitting Form R(s)
and/or Form A(s).

A.2.a.   How to  Submit Form R(s)
         and/or Form A(s) Electronically
         to EPA via the Central Data
         Exchange (Using the  TRI-
         MEweb Application)

The preferred  method to  report to TRI  is by the
use of  the  TRI-Made Easy web  (TRI-MEweb)
application via EPA's Central Data Exchange
(CDX).  TRI-MEweb  is an intelligent, web-based
version of the popular TRI-ME software. There are
several advantages to using TRI-MEweb. They are
                   Toxics Release Inventory Reporting Forms and Instructions
                                            1

-------
as  follows: your  prior  year  data will  be pre-
populated,  electronic  signature that allows for
paperless  filing, higher  data quality and instant
confirmation  that  EPA   has  received   your
submission. Facilities will be able to  submit
reports electronically via TRI-MEweb and submit
their forms through  the  Internet via CDX. CDX
allows  facilities  to  file   a   paperless  report,
significantly reducing data errors,  and receive
instant receipt confirmation of their submission.
Facilities that use  TRI-MEweb  to submit through
the Internet via  CDX,  and  reside in a  state
participating in the TRI State Data Exchange, will
have their  forms sent simultaneously to EPA and
their   respective    state   officials  via   the
Environmental  Information Exchange Network.
Once a TRI submission is certified,  it will  be
electronically forwarded to  state officials and your
obligation to report to EPA and your state will be
satisfied.

EPA encourages you to use TRI-MEweb to submit
your TRI submission(s). TRI-MEweb allows you
to submit  a completely paperless  report to  EPA
(Internet submissions are not  available for trade
secret claims).  If  you choose  to submit via the
Internet, do not send duplicate  paper copies of the
reports to  the data processing center. Please  be
aware that  if your facility does  not reside in a state
participating in  the   TRI  State Data  Exchange,
submitting via the Internet does not satisfy your
state reporting requirements for your facility. You
must  report to your  state  separately and in the
required format specified by your state.

Former  TRI-ME  desktop/CD  filers that  have
submitted  their  reports  through CDX in  prior
reporting years,  will need  to  "edit  your current
account profile" in their My CDX account to add
the new  TRI-MEweb application into their CDX
account.     In  addition,  any  active  registered
certifying official within TRI-ME desktop/CD will
also need  to  add TRI-MEweb into their CDX
account profile and  list all TRIFIDs assigned to
the certifying  official  into their  profile.   All
assigned TRIFIDs will be  listed in  an electronic
signature  agreement  (ESA) document  that will
need to be printed,  signed and sent by mail to
EPA's  Data  Processing  Center  for  approval.
ESA's typically  require five (5) business days to
be  processed  and  approved.  ESA's  for  TRI-
MEweb are only required once for new certifiers
and for   former  TRI-ME desktop/CD   active
certifying officials.  ESA's needs to be approved
by EPA before a certifying  official can proceed to
finalize the certification of a facility's Form R or
A submission and fulfill their EPCRA Section 313
reporting requirements.

For  questions  or additional  information  about
CDX, please see: http://www.epa.gov/cdx
A.2.b   How to Submit Paper Form
         R(s) and/or Form A(s)

It  is  EPA's ultimate goal to move  away  from
processing paper submissions and receive all TRI
submissions via CDX.  Although  EPA strongly
discourages  paper  submissions due to increased
possibility  of errors,  paper  submissions  are
currently still accepted. Paper submissions must be
sent to both EPA and the  state (or the designated
official  of an Indian tribe). If a  report  is not
received by  both  EPA  and  the   state  (or the
designated   official  of  an  Indian  tribe),  the
submitter is considered out of compliance and
subject   to   enforcement   action.   Facilities
submitting  paper  forms  must use the  current
reporting  year  forms;  out-of-date  forms  will
considered  out of compliance. Send paper forms
by regular mail to:

TRI Reporting Center
P.O. Box 10163
Fairfax, VA 2203 8

Send  paper forms  by certified mail or overnight
mail (i.e. Fed Ex, UPS, etc.) to:

CGI Federal, Inc
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033

Also send a copy of the report to the state in which
the facility is  located. "State" also includes: the
District  of  Columbia,  the  Commonwealth  of
Puerto Rico, Guam, American Samoa,  Marshall
Islands,   the   U.S.   Virgin    Islands,    the
Commonwealth of the Northern Mariana Islands,
and any other jurisdiction  and Indian  Country.
Refer to Appendix  E for the appropriate  state
submission addresses.

Facilities located on  Indian land  should send a
copy  to the  Chief  Executive  Officer  of the
applicable Indian tribe. Some tribes have entered
into a cooperative  agreement with  states;  in this
case,  report submissions  should  be  sent  to the
entity designated in the cooperative agreement.
                    Toxics Release Inventory Reporting Forms and Instructions

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                                      General Information
A. 3    Trade Secret Claims

For  any EPCRA  Section  313  chemical  whose
identity  is claimed  as trade secret, you must
submit to EPA two versions of the substantiation
form as prescribed in 40 CFR Part 350, published
July 29, 1988, in the Federal Register (53  FR
28772)  as  well as two versions  of  the EPCRA
Section  313  report.  The  current substantiation
form  is  available  on  the  TRI  website   at
http://www.epa.gov/tri/report/index.htmtfforms.
One set  of reports, the unsanitized version, must
provide the actual identity of the EPCRA Section
313  chemical. The  other set of reports, i.e.,  the
"sanitized" version, must provide a generic class
or category for the chemical that is structurally
descriptive of the EPCRA Section 313 chemical. If
EPA deems the trade  secret substantiation form
valid, only the sanitized set of forms will be made
available to the public.

Use  the  order form in this document to obtain
copies of the  rule and substantiation form. Further
explanation of the  trade  secret provisions is
provided in Part I, Sections 2.1 and 2.2, and Part
II, Section 1.3, of the instructions.

In summary, a complete  report to EPA  for an
EPCRA  Section 313 chemical claimed as a trade
secret must include all of the following:

•   A completed unsanitized version of Form R or
    Form A report including the EPCRA Section
    313  chemical  identity  (staple  the  pages
    together); and
•   A sanitized version of a completed Form R or
    Form A report in which the EPCRA Section
    313 chemical  identity items (Part II, Sections
    1.1 and 1.2) have been left blank but in which
    a generic  chemical name that is structurally
    descriptive has been supplied (Part II, Section
    1.3) (staple the pages together); and
•   A  completed  unsanitized version of a trade
    secret substantiation  form (staple the pages
    together); and
•   A sanitized version of a completed trade secret
    substantiation form (staple the pages together).

Securely fasten all four reports together.

Some  states  also  require submission  of both
sanitized  and unsanitized  reports  for EPCRA
Section 313 chemicals whose identity is claimed
as a trade secret.  Others require only a sanitized
version. Facilities may jeopardize the trade secret
status  of an EPCRA Section  313 chemical by
submitting an unsanitized version of the EPCRA
Section 313 report to a state agency or Indian tribe
that does not require unsanitized forms. You may
identify   an   individual   state's  submission
requirements by contacting the appropriate state
designated  EPCRA  Section  313  contact  (see
Appendix E).

Where to send your trade secret submission

Please send only trade secret submissions to the
P.O. Box below. Send trade secret submissions by
regular mail to:

        Attention: EPCRA Substantiation
        Packages
        TRI Reporting Center
        P.O. Box 10163
        Fairfax, VA 2203 8

Send trade secret submissions by certified mail or
overnight mail (i.e. Fed Ex, UPS, etc.) to:

        Attention: EPCRA Substantiation
        Packages
        CGI Federal, Inc.
        c/o EPA Reporting Center
        12601 Fair Lakes Circle
        Fairfax, VA 22033

A.4    Recordkeeping

Sound recordkeeping practices are essential  for
accurate and efficient TRI reporting. It is in the
facility's interest, as well as  EPA's, to maintain
records properly.

Facilities must keep a copy of each report filed for
at least three years  from the  date of submission.
These  reports will  be of use  when completing
future reports.

Facilities  must also maintain those documents,
calculations,  worksheets,  and other  forms upon
which  they relied to gather information for prior
reports. In  the event of a  problem with  data
elements on a facility's Form R or Form A report,
EPA may request documentation from the facility
that supports the information reported.

EPA may conduct data quality reviews of Form R
or Form A submissions.  An essential component
of this process involves reviewing a facility's
                   Toxics Release Inventory Reporting Forms and Instructions

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records for  accuracy  and  completeness.  EPA
recommends that facilities keep a record for those
EPCRA Section 313 chemicals for which they did
not file EPCRA Section 313 reports.

A partial list  of records, organized by year, that a
facility should maintain include:

•   Previous years' EPCRA Section 313 reports;
•   EPCRA  Section  313  Reporting  Threshold
    Worksheets;
•   Engineering calculations and other notes;
•   Purchase  records from suppliers;
•   Inventory data;
•   EPA  (NPDES)   permits  and  monitoring
    reports;
•   EPCRA Section312 Tier II Reports;
•   Monitoring records;
•   Flowmeter data;
•   RCRA Hazardous Waste Generator's Report;
•   Pretreatment reports filed by the facility with
    the local government;
•   Invoices from waste management companies;
•   Manufacturer's   estimates    of  treatment
    efficiencies;
•   RCRA manifests;
•   Process diagrams that indicate  emissions and
    other releases; and
•   Records  for  those  EPCRA  Section  313
    chemicals for which they  did not file EPCRA
    Section 313 reports.

A. 5   How to Revise or Withdraw TRI
       Data

EPA  has  received several  questions relating to
withdrawing  and revising TRI data submitted by
facilities, such as:

•   What are  the reasons for revising?

•   How do I revise my submission?

•   To whom should this request be sent?

Submitting a Request to Revise TRI Data

Facilities  that filed a  Form  R  and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to revise a form that was
previously submitted, stored in the Toxics Release
Inventory  Processing System  (TRIPS), and made
available to the public through Envirofacts  and
TRI Explorer. Facilities may request a revision for
one or more of the following reasons:

      RR1 - New Monitoring Data
      RR2 - New Emission Factor(s)
      RR3 - New Chemical Concentration Data
      RR4 - Recalculation(s)
      RR5 - Other Reason(s)

The  revision code(s)  should  be entered in the
"Revision" box on the first page of the reporting
form. You may enter up to two revision codes on
the form.

Please note that late submissions for chemicals not
reported  in a  previous reporting  year are  not
considered revisions for that year.

How do I revise my submission(s)?

If you have determined that your facility wishes to
revise a TRI  submission, you must  send  your
revised  report to  EPA  and the appropriate  state
agency.  For submitting  a revision to EPA, please
use one of the following methods:

    •  EPA will accept revisions for Reporting
       Year 2005 through current year via TRI-
       MEweb and paper.
    •  EPA  will  accept  all  revisions prior to
       Reporting  Year 2004  and  beyond  on
       magnetic  media created using  TRI-ME
       software or paper.

1. TRI-MEweb. The preferred method for revising
TRI forms from Reporting Year 2005 through the
current year is to use TRI-MEweb. For more
information regarding access to TRI-MEweb,
please visit http://www.epa.gov/tri.  TRI-MEweb
provides several advantages compared to hard-
copy reporting, such as pre-populating the form
with the previous year's data, allowing reporters to
electronically sign and submit the form over the
Internet, providing automated data quality checks,
and electronically confirming EPA's receipt of a
submitted form. If you have questions about
accessing TRI-MEweb, please refer to the TRI-ME
web page at
http://www.epa.gov/tri/report/software/index.htmtf
usetrime

2. Hard Copy  Form.  EPA strongly  discourages
paper submissions due to the increased possibility
of data  entry errors; however, if necessary,  you
may revise  a previously submitted hard-copy form
                   Toxics Release Inventory Reporting Forms and Instructions

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                                     General Information
or revisions for Reporting Year 2004 and beyond
by using either 1) a photocopy of the original or 2)
a blank form.

•   Photocopy of Original Submission. You may
    submit  a  photocopy  of  your  original
    submission   (from  your   file)   with  the
    corrections made in blue ink. Please re-sign
    and re-date the  certification statement on Page
    1. For RY 2007 revisions and beyond,  please
    enter the appropriate revision code(s). For RY
    2006 and prior years, please  enter an "X" in
    the space marked "Enter 'X' here  if this is a
    revision," on Page 1 of the form.

•   Blank Form. Hard copy submissions may be
    submitted using the form applicable for that
    particular reporting year or the most  recent
    form available.  You  can request  prior year
    reporting  forms at tridocs@epa.gov. For RY
    2007 revisions and beyond,  please enter all
    information including the appropriate revision
    code(s). For RY 2006 and prior years,  please
    enter all information including an  "X" in the
    space  marked  "Enter  'X'  here  if this is  a
    revision," on Page 1 of the form.  Please sign
    and date the certification statement on Page 1.

Send  revision requests by regular  mail to the
following address:

       Attention: TRI Revision Request
       TRI Reporting Center
       P.O. Box 10163
       Farifax, VA 22038

Send  revision  requests  by  certified mail  or
overnight mail to the following address:

       Attention: TRI Revision Request
       CGI Federal, Inc.
       c/o EPA Reporting Center
       12601 Fair Lakes Circle
       Fairfax, VA 22033

Submitting a Request to Withdraw TRI Data

Facilities that filed a  Form  R and/or Form A
Certification Statement under EPCRA Section 313
may submit a request to withdraw a form that was
previously submitted, stored in the Toxics Release
Inventory  Processing System (TRIPS), and made
available to the  public through  Envirofacts and
TRI Explorer.  EPA  may  periodically  review
withdrawals. Facilities may request a withdrawal
for one or several reasons, such as:

•  WT1 - Did not meet the reporting threshold
   for  manufacturing, processing, or  otherwise
   use

•  WT2 - Did not meet the reporting threshold
   for number of employees

•  WT3 - Not in a covered NAICS Code

•  WO1 - Other reason(s)

The withdrawal code(s)  should be entered in the
"Withdrawal"  box on  the  first  page  of the
reporting  form.  You  may  enter  up  to two
withdrawal codes on the form.

How do I withdraw my submission(s)?

If you have determined that your facility wishes to
withdraw a TRI submission, you must send your
request to EPA and the appropriate state agency.
For submitting a withdrawal to EPA,  please use
one of the following methods:

1.  TRI-MEweb.   The   preferred method  for
requesting a withdrawal of a previously submitted
TRI form from Reporting Year 2005 through the
current year is TRI-MEweb.  For more information
regarding  access   to  TRI-MEweb, please  visit
http://www.epa.gov/tri/report/software/index.htmtf
usetrime

2. TRI-ME via CDX. For the RY 2002 through
2004 versions of the software, withdrawals may be
submitted  electronically   using   the   TRI-ME
software and  submitting  the report via  CDX and
the Internet.  You  can  download the  TRI-ME
software at http ://www.epa. gov/tri

3. Hard  Copy  Form.  All  other  withdrawal
requests  may be  submitted  by  hard copy  as
follows:

•  Reporting  Year  2007  Forward.   You  may
   submit  a  photocopy   of   your  original
   submission (from your  file). Using blue ink,
   re-sign and re-date the certification statement
   on  Page   1   and   enter  the  appropriate
   withdrawal code(s) in the space provided  on
   Page 1 of the form.

•  Reporting Year 2006 and Prior Years. Please
   submit a photocopy  of the form you wish to
                   Toxics Release Inventory Reporting Forms and Instructions

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    withdraw (from your file), and attach - as a   A. 7   HOW to Obtain the TRI
    cover page - Page  1 of the current year's
    reporting form, which includes a field for the
    withdrawal codes. Using blue ink, please sign
    and date the certification statement and enter
    all  information  including  the  appropriate
    withdrawal code(s)  in the space provided on
    Page 1 of the current year's form.

Send  withdrawal requests by regular mail to the
following address:

       Attention: TRI Withdrawal Request
       TRI Reporting Center
       P.O. Box 10163
       Fairfax, VA 22038

Send  withdrawal requests by  certified  mail or
overnight mail to the following address:

       Attention: TRI Withdrawal Request
       CGI Federal, Inc
       c/o EPA Reporting Center
       12601 Fair Lakes Circle
       Fairfax, VA 22033

A. 6   When the Report Must Be
       Submitted

As specified in EPCRA Section 313, the report for
any calendar year must be submitted on or before
July 1 of the following year whether using Form R
or Form  A. If the reporting deadline falls on  a
Saturday or Sunday,  EPA will accept the forms
which are postmarked on the following  Monday
(i.e., the  next business day).  If you submit using
TRI-MEweb  via  the  Central  Data  Exchange
(CDX), you will receive your Facility Data Profile
(FDP) in an expedited  fashion. Any voluntary
revision  to a report can be  submitted  anytime
during the  calendar year for the current or any
previous   reporting   year. However,  voluntary
revisions for the current reporting year should be
submitted by July 31 in order to be included in that
year's TRI National Analysis. Always remember
to review  your  FDP.  The FDP  presents  the
information you have submitted to  EPA. If the
Technical Contact provided an email address  in
the Form R/Form A, they will receive an email
notifying them when  their FDP has been  updated
and posted to the FDP website. You can retrieve
your FDPs at http://www.triefdp.org. If you have
questions regarding your FDP,  please send an e-
mail to tri.efdp@epacdx.net or call 703-227-7644.
       Reporting Forms
Copies of both forms are included in the first part
of this document. The forms and related guidance
documents may also be obtained from EPA's TRI
web site: http://www.epa.gov/tri
                   Toxics Release Inventory Reporting Forms and Instructions

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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
B.    How to Determine if Your
       Facility Must Submit  a
       Form  R or Is Eligible  to
       Use Form A
This section will help you determine whether you
must submit an EPCRA Section 313 report (EPA
Form R or Form A Certification Statement). This
section discusses  EPCRA  Section 313  reporting
requirements such as the number of  full-time
employees, primary NAICS  code, and  chemical
activity threshold quantities. The EPCRA Section
313 chemicals and chemical categories subject to
reporting are listed in Table II (also see 40 CFR
372.65). (See Figure 1 for more information.)

B.I   Full-Time Employee
       Determination
The number of full-time employees is dependent
only upon the total number of hours worked by all
employees and other individuals (e.g., contractors)
for the facility during the calendar year and not the
number of persons working. Therefore, a full-time
employee, for purposes of EPCRA Section 313
reporting, is  defined as 2,000 work hours per year.
When    making    the    full-time    employee
determination, the facility must consider all paid
vacation  and sick leave used as hours worked by
each employee. In addition, EPA interprets  the
hours worked by an employee to include paid
holidays. To determine the number of  full-time
employees working for your facility,  add up  the
hours worked  by  all  employees  during  the
calendar  year, including contract employees and
sales and support staff working for the facility, and
divide the total by 2,000 hours.  The result  is  the
number of full-time employees. In other  words, if
the total number of hours worked by all employees
for your facility is 20,000 hours or more, your
facility meets the ten employee threshold.

Examples:

•   A facility consists of 11 employees who each
    worked  1,500 hours   for the  facility  in a
    calendar year. Consequently, the total number
    of hours worked by  all  employees for  the
    facility during the  calendar  year is 16,500
    hours. The number of full-time employees for
    this  facility is equal to 16,500 hours divided
    by 2,000 hours per full-time employee, or 8.3
    full-time employees. Therefore, even though
    11 persons worked for this facility during the
    calendar year, the number of hours worked is
    equivalent  to  8.3  full-time employees.  This
    facility does not meet the  employee criteria
    and is  not subject to EPCRA Section 313
    reporting.

•   Another facility consists of six workers and
    three sales  staff. The six workers each worked
    2,000 hours for the facility during the calendar
    year. The sales staff also each worked  2,000
    hours during the calendar year although they
    may have been on the  road half of the year. In
    addition, five  contract employees  were hired
    for a period during which  each worked 400
    hours for the facility. The total  number  of
    hours is equal to the time worked by the
    workers (12,000 hours),  plus the time worked
    by the sales staff for the facility (6,000 hours),
    plus  the  time  worked  by  the   contract
    employees   (2,000 hours),  or 20,000 hours.
    Dividing the 20,000 hours by 2,000 yields  10
    full-time employees. This facility has met the
    full-time employee criteria and may be subject
    to reporting if the other criteria are met.

B. 2   Primary NAICS Code
       Determination

Beginning  with  2006   EPCRA  Section  313
reporting,  the  TRI  Program  requires  North
American Industry Classification System (NAICS)
codes instead of Standard  Industrial Classification
(SIC) codes. Please refer to the TRI Program's
final rule titled Community Right-to-Know; Toxic
Chemical  Release  Reporting  Using   North
American Industry Classification System (NAICS)
published in the Federal Register on June 6, 2006
(71FR32464).

Beginning  with Reporting Year 2008,  facilities
should use  2007 NAICS codes.  EPA published a
final rule on June 9,  2008 to  incorporate 2007
Office  of Management  and  Budget  (OMB)
revisions and  other  corrections to the  NAICS
codes used for  TRI Reporting.  [Federal Register
(FR) notice 73 FR 32466.] With this rule, facilities
are  required to use 2007 NAICS codes  on TRI
reporting forms that are  due on July  1,  2009,
covering releases and other waste management
quantities at the facility for 2008.

The full list of NAICS  codes  for facilities that
must report to TRI (including  exceptions and/or
                   Toxics Release Inventory Reporting Forms and Instructions

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limitations) if all other threshold determinations
are met can be found in Table I and also at the TRI
web                   site                   at
http://www.epa.gov/tri/lawsandregs/naic/ncodes.ht
m.
http://www.epa.gov/tri/lawsandregs/naic/ncodes.ht
m The facility should determine its own NAICS
code (s), based on its activities on-site, using the
NAICS Manual and by referring to  the extensive
OMB  crosswalk  tables  found  on  the  Census
Bureau  website:   http: //www. census. gov.  State
agencies  and other  organizations   may  assign
NAICS codes on a different basis  than  the one
used by the SIC Manual. However, for purposes of
EPCRA   Section   313   reporting,   these  state
assigned codes should not be  used if they differ
from ones assigned using the NAICS Manual.

The TRI Information Center can assist facilities
with  determining  which   NAICS  codes  are
assigned  for   specific  business   activities   as
referenced  in  the NAICS  Manual. Clothbound
editions of the NAICS Manual are available in
most major libraries or may be ordered through the
National Technical Information Service, 5285 Port
Royal  Road,  Springfield,  VA  22161, 703-605
6000.  The  access  number for  the  hardbound
manual is PB2002-101430,  $49.00+ shipping  and
handling.  The access number for the  CD-ROM
version with  search  and  retrieval  software is
PB2002-502024, $60 + shipping and handling.
      Paperwork Reduction Act Notice: The annual public burden related to the Form R, which is
      approved under OMB Control No. 2070-0093, is estimated to average 29.6 hours per response
      for non-PBT chemicals and 51.3 hours per response for PBT chemicals. The annual public
      burden related to the Form A, which is approved under OMB Control No. 2070-0143, is
      estimated to average 20.5 hours per response for a facility filing on one non-PBT chemical, and
      35.89 hours per response for a facility filing on one PBT chemical.

             Burden means the total time, effort,  or financial resources  expended by persons to
      generate, maintain, retain, or disclose or provide information to or for a Federal agency. This
      includes the time needed to review instructions; develop, acquire, install, and utilize technology
      and systems for the purposes of collecting, validating, and verifying information, processing and
      maintaining information, and disclosing and providing information; adjust the existing ways to
      comply with any previously applicable instructions  and requirements; train personnel to be able
      to  respond to  a collection of information;  search  data  sources; complete and review the
      collection of information; and transmit or otherwise disclose the information. An agency may
      not conduct or sponsor, and a person  is not required to respond to, a collection of information
      unless it displays a currently valid OMB control number. The OMB control numbers for EPA's
      regulations are  listed in 40 CFR Part 9 and 48 CFR Chapter 15.

             Send comments on the Agency's need for this information, the accuracy of the provided
      burden estimates, and any suggested methods for minimizing respondent  burden, including
      through  the  use of automated collection  techniques,  to  the  Director,  Collection Strategies
      Division, U.S.  Environmental Protection  Agency  (2822),  1200 Pennsylvania  Ave.,  NW,
      Washington, D.C. 20460; and to the  Office of Information and Regulatory Affairs, Office of
      Management and Budget, 725  17th  Street,  NW, Washington, DC 20503, Attention: Desk
      Officer  for  EPA.  Include  the  EPA   ICR  number  and OMB  control  number   in  any
      correspondence.

             The  completed  forms should  be  submitted  in  accordance  with the  instructions
      accompanying the form, or as specified in the corresponding regulation.
                   Toxics Release Inventory Reporting Forms and Instructions

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      How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
 Does your facility have 10 or more full-
   time employees or the equivalent?

      (see definition under B.I)
                  YES
 Is your facility's primary NAICS Code
 included on the EPCRA Section 313
 list? Or is your facility a Federal facility?

        (see B.2 and Table 1)
                  YES
Does your facility manufacture, process, or
  otherwise use EPCRA Section 313
   chemicals and chemical categories?

   (see Table II, B.3-B.5, and D.1-D.7)
                  YES
   Does your facility exceed any of the
  thresholds for a chemical or chemical
 category (after excluding quantities that
 are exempt from threshold calculations)
                  YES
 AN EPCRA SECTION 313 REPORT
 IS REQURED FOR THE CHEMICAL OR
       CTTFMTC AT, C ATFYIORV
                  YES
 Is this chemical or chemical category identified
 as Persistent, Bioaccumulative, and Toxic
 (PBT)?
       YES
NO
           NO
           NO
           NO
            NO
           STOP

NO EPCRA SECTION

      313 REPORTS

REQUIRED FOR ANY

      CHEMICALS
                    Is the amount manufactured, OR processed, OR otherwise used less than
                    or equal to 1,000,000 pounds and is the reportable amount less than or
                    equal to 500 Ibs/year?
                             NO
                                      YES
 FORM R IS REQUIRED FOR THIS
    CHEMICAL OR CHEMICAL
 CATEGORY (FORM A CANNOT BE
          SUBMITTED)
                  FORM A OR FORM R IS REQUIRED
                  FOR THIS CHEMICAL CATEGORY
               Figure 1. EPCRA Section 313 Reporting Decision Diagram
                Toxics Release Inventory Reporting Forms and Instructions

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B.2.a.   Auxiliary Facilities

Under the Standard Industrial Classification (SIC)
system, an auxiliary facility was defined as one
that  supported another  covered establishment's
activities   (e.g.,   research   and   development
laboratories, warehouses, and storage facilities).
An auxiliary facility could assume the SIC code of
another  covered  establishment  if  its  primary
function was  to  service  that other  covered
establishment's operations.  The  North American
Industry Classification  System  (NAICS),  that
replaces the SIC system for TRI reporting, does
not recognize the concept  of auxiliary  facilities
and assigns NAICS codes  to all establishments
based on economic activity.  In its  rulemaking,
"Toxic  Chemical Release Reporting  Using North
American  Industry  Classification System,"  the
TRI   Program  has  adopted  NAICS  for  TRI
reporting and also the NAICS treatment of former
"auxiliary  facilities"  as  entities  with their  own
distinct NAICS code.

B.2.b.   Multi-establishment Facilities

Your  facility may include multiple establishments
that  have  different  NAICS  codes.  A  multi-
establishment facility is a facility that consists of
two or more distinct and separate economic units.
If your facility is a multi-establishment facility,
calculate  the  value  added  of the   products
produced, shipped, or services provided from each
establishment within the facility  and then use the
following rule to determine if your facility meets
the NAICS code criterion:

•  If the  total  value  added  of  the  products
   produced,  shipped, or  services  provided at
   establishments with covered NAICS  codes is
   greater than 50 percent  of the value added of
   the  entire facility's products  and services, the
   entire facility meets the NAICS code criterion.

•  If any  one  establishment  with a  covered
   NAICS code  has a value added of services or
   products shipped or produced that is greater
   than any  other  establishment   within   the
   facility (40 CFR  Section 372.22(b)(3))  the
   facility also meets the NAICS code criterion.

The   value added  of  production   or   service
attributable to a particular establishment may be
isolated by subtracting the product value  obtained
from other  establishments within the  same facility
from  the total product or  service  value of the
facility. This procedure eliminates the potential for
                              "double  counting"  production  and  services  in
                              situations where establishments  are  engaged  in
                              sequential  production or service activities  at  a
                              single facility.

                              Examples include:

                              •   A facility  in coating,  engraving  and  allied
                                  services  has two establishments.  The  first
                                  establishment,  a general automotive repair
                                  service, is in NAICS code 811113 (SIC 7537),
                                  which is not a covered NAICS code. However,
                                  the second establishment, a metal paint shop is
                                  in NAICS code 332812  (SIC  3479, which is a
                                  covered NAICS code).  The metal paint  shop
                                  paints   the   parts   received  from  general
                                  automotive   repair   service.  The  facility
                                  determines the  product  is worth $500/unit as
                                  received from the general automotive repair
                                  service (in non-covered  NAICS code 811113)
                                  and the value of the product is $1500/unit after
                                  processing by the metal  paint shop (in covered
                                  NAICS  code 332812). The value added by the
                                  metal paint shop is obtained by subtracting the
                                  value  of the  products  from  the  general
                                  automotive  repair service from  that  of the
                                  value of the products of the metal paint shop.
                                  (In  this  example,  the  value   added  =
                                  $l,500/unit  - $500/unit = $l,000/unit.) The
                                  value added ($l,000/unit) by the establishment
                                  in NAICS  code 332812  is more  than 50
                                  percent  of the  product  value. Therefore, the
                                  facility's  primary NAICS code  is 332812,
                                  which is a covered NAICS code.

                              •   A food  processing establishment in a facility
                                  processes  crops  grown  at the facility  in  a
                                  separate establishment. To determine the value
                                  added of the products of each establishment
                                  the facility could first determine the value of
                                  the  crops   grown   at  the   agricultural
                                  establishment,   and   then   calculate   the
                                  contribution   of   the   food    processing
                                  establishment by subtracting the crop  value
                                  from the total  value of the  product  shipped
                                  from the processing establishment (value  of
                                  product shipped from processing - crop value
                                  = value of processing establishment).

                              A covered multi-establishment facility must make
                              EPCRA    Section    313   chemical   threshold
                              determinations and, if required,  must  report all
                              relevant  information  about releases  and  other
                              waste management activities, and source reduction
                              activities associated with an EPCRA Section 313
                              chemical  for  the  entire  facility,  even   from
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
establishments that are not in covered  NAICS
codes.   EPA  realizes,  however,  that  certain
establishments in  a multi-establishment  facility
can be, for all practical purposes,  separate and
distinct business units. Therefore,  while threshold
determinations  must  be  made  for  the entire
facility, individual  establishments  which compose
the entire  facility  may  report their individual
releases and  other waste  management activities
separately.  However, the total  releases and other
waste management quantities for the entire facility
must be represented by the  sum of  the releases and
other  quantities  managed  as waste  reported by
each of the  separate establishments.

B.2.c.   Property Owners

You are not required to report if you merely own
real estate on which a facility covered by this rule
is  located;  that  is, you have  no  other  business
interest in the operation of that facility (e.g., your
company owns an industrial park).  The operator of
that  facility, however,  is subject  to reporting
requirements.

B.3   Activity Determination

B.3.a.   Definitions of Manufacture,
         Process, and Otherwise Use

Manufacture: The term "manufacture" means to
produce, prepare, compound, or import an  EPCRA
Section 313 chemical. (See Part II, Section 3.1 of
these instructions for further clarification.)

Import is defined as causing the EPCRA Section
313 chemical to be imported  into  the  customs
territory  of the  United  States.  If you order an
EPCRA  Section  313  chemical  (or a   mixture
containing the chemical) from a foreign  supplier,
then you have imported the chemical when that
shipment arrives at your facility  directly from a
source  outside of the United States.  By  ordering
the chemical, you  have caused it  to  be imported,
even  though  you  may  have  used  an import
brokerage firm as  an agent to obtain the  EPCRA
Section 313 chemical.

Do Not Overlook Coincidental Manufacture

The    term   "manufacture"    also   includes
coincidental production of  an EPCRA Section 313
chemical (e.g., as  a byproduct or impurity) as a
result of the manufacture, processing, otherwise
use or disposal of another chemical or mixture of
chemicals. In the case of coincidental production
of  an impurity  (i.e., an EPCRA  Section  313
chemical that remains  in  the  product  that  is
distributed   in   commerce),   the   de  minimis
exemption, discussed in  Section B.3.c of these
instructions, applies. The de  minimis exemption
does  not apply to byproducts (e.g., an EPCRA
Section  313  chemical that is separated  from a
process stream and further processed or disposed).
Certain  EPCRA  Section  313 chemicals may be
manufactured as  a  result  of wastewater treatment
or  other  treatment  processes.  For  example,
neutralization of wastewater containing nitric  acid
can result in the coincidental manufacture of a
nitrate  compound   (solution),  reportable as  a
member of the nitrate compounds category.

Process:  The   term   "process"   means  the
preparation  of a  listed EPCRA  Section  313
chemical, after its manufacture, for distribution in
commerce. Processing is usually the incorporation
of an  EPCRA Section 313 chemical into a product
(see Part II, Section 3.2  of these instructions for
further  clarification). However, a  facility may
process  an  impurity  that  already exists in a raw
material   by  distributing   that  impurity  in
commerce. Processing includes preparation of the
EPCRA  Section  313  chemicals  in the same
physical state or chemical form as that received by
your facility, or preparation that produces a change
in physical state  or chemical form. The term  also
applies to the processing of a mixture  or other
trade  name product  (see Section B.4.b  of these
instructions) that contains a listed EPCRA Section
313 chemical  as one component.

Otherwise Use: The term "otherwise use" means
any use  of an  EPCRA  Section 313  chemical,
including  an  EPCRA   Section  313  chemical
contained in a mixture or other trade name product
or  waste,  that  is  not   covered by the  terms
manufacture  or  process. Otherwise use  of an
EPCRA Section  313 chemical  does not  include
disposal,   stabilization   (without    subsequent
distribution  in  commerce),  or treatment   for
destruction unless:

(1) The EPCRA Section 313 chemical that  was
disposed, stabilized, or treated for destruction was
received from off-site for the purposes of further
waste management;
                                                 Or
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                                                 313  chemical  where  no  repackaging  of  the
(2) The EPCRA  Section 313  chemical  that was    EPCRA  Section  313 chemical occurs does  not
disposed, stabilized, or treated for destruction was    constitute an otherwise use or processing of the
manufactured  as  a result of waste management    EPCRA Section 313 chemical. (See 62 FR 23846
activities on materials received from off-site for    and Part II, Section 3.3 of these  instructions for
the purposes  of  waste  management  activities.    further clarification).
Relabeling or redistributing of the EPCRA Section
 Example 1: Coincidental Manufacture

     Q Your company, a nitric acid manufacturer, uses aqueous ammonia in a waste treatment system
        to neutralize an acidic wastewater stream containing nitric acid. The reaction of ammonia and
        nitric acid produces a solution of ammonium nitrate. Ammonium nitrate (solution) is reportable
        under the nitrate compounds category and is manufactured as a byproduct. If the ammonium
        nitrate is produced  in a quantity that exceeds the 25,000-pound manufacturing  threshold, the
        facility must report under the nitrate compounds category.

        The aqueous ammonia is considered to be otherwise used and 10 percent of the total aqueous
        ammonia would be counted towards the 10,000-pound otherwise  use threshold. Reports for
        releases of ammonia must also include 10 percent of the total aqueous  ammonia from the
        solution of ammonium nitrate (see the qualifier for the ammonia listing).

     Q As another example, combustion of coal or other fuel in boilers/furnaces can result in the
        coincidental manufacture  of metal  category  compounds and sulfuric  acid (acid aerosols),
        hydrochloric acid (acid aerosols), and hydrogen fluoride.
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
 Example 2: Typical Process and Manufacture Activities

    G  Your company receives toluene, an EPCRA Section 313 chemical, from another facility, and
        reacts the toluene with air to form benzoic acid, which the company distributes in commerce.
        Your company processes toluene and manufactures and processes benzoic acid. Benzoic acid,
        however, is not an  EPCRA  Section 313 chemical  and thus does  not  trigger  reporting
        requirements.
    G  Your facility combines toluene purchased from a supplier with various materials to form paint
        which it then sells. Your facility processes toluene.
    G  Your company receives a nickel compound (nickel compounds is a listed EPCRA Section 313
        chemical category) as a bulk  solid  and performs various  size-reduction operations  (e.g.,
        grinding) before packaging the  compound in 50-pound bags, which the company sells.  Your
        company processes the nickel compound.
    G  Your  company receives  a prepared mixture of resin  and chopped fiber to be used in the
        injection molding of plastic products. The resin contains a listed EPCRA Section 313 chemical
        that becomes incorporated into the plastic, which the company distributes in commerce.  Your
        facility processes the EPCRA Section 313 chemical.
    G  In the combustion of coal or oil, metal category compounds may be produced from  either the
        parent metal or a metal compound contained in the coal  or oil. If a metal undergoes a change of
        valence, a  metal  compound is considered to be manufactured.  For example, during the
        combustion process copper  in valence state zero changes to copper in valence state +2 in a
        compound  such as copper  (II)  oxide (CuO).  Furthermore, a metallic compound  could be
        transformed to another metallic compound without a change in valency  (e.g., copper (II)
        chloride (CuC12) is transformed to copper (II) oxide  (CuO)). The  transformation  to a new
        compound  by  combustion  without a change in  valence  state is  also  considered  to be
        "manufactured" for purposes of EPCRA Section 313.
 Example 3: Typical Otherwise Use Activities

    G  When your facility cleans equipment with toluene, you  are otherwise using toluene. Your
        facility also separates two components of a mixture by dissolving one component in toluene,
        and subsequently recovers the toluene from the process for reuse or disposal. Your facility
        otherwise uses toluene.
    G  A covered facility  receives a waste containing 12,000 pounds  of Chemical A, a non-PBT
        EPCRA Section 313 chemical, from off-site. The facility treats the waste, destroying Chemical
        A and in the treatment process manufactures 10,500 pounds of Chemical B, another non-PBT
        EPCRA Section 313  chemical. Chemical B is disposed on-site.  Since the waste containing
        Chemical A was received from off-site for the purpose of waste management, the amount of
        Chemical A must be included in the otherwise use threshold determination for Chemical A. The
        otherwise use threshold for a non-PBT chemical is  10,000 pounds and since the amount of
        Chemical A exceeds  this threshold, all  releases and other waste management  activities for
        Chemical A must be reported. Chemical B was manufactured  in the treatment of a waste
        received from off-site. The facility disposed of Chemical B on-site. Since Chemical B  was
        generated  from waste  received  from  off-site  for  treatment for  destruction,  disposal, or
        stabilization, the disposal of Chemical B is considered to be an otherwise use. Thus, the amount
        of Chemical B must  be considered in the otherwise use  threshold determination.  Thus, the
	reporting threshold for Chemical  B has also been exceeded and all releases and other waste

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        management activities for Chemical B must be reported.
 B.3.b.  Persistent Bioaccumulative
         Toxic (PBT) Chemicals and
         Chemical Categories Overview
On October 29, 1999, EPA published a final rule
(64  FR  58666)  adding certain  chemicals  and
chemical categories to the EPCRA Section 313 list
of toxic  chemicals and lowering the reporting
threshold  for persistent bioaccumulative  toxic
(PBT) chemicals. In addition, on January 17, 2001
EPA published a final  rule (66  FR  4500)  that
classified  lead and lead   compounds  as  PBT
chemicals and lowered their reporting  thresholds.
The lower reporting thresholds for lead applies to
all  lead  except when  lead  is  contained  in  a
stainless steel, brass or bronze alloy.

Dioxin   and   dioxin-like   compounds,   lead
compounds, mercury compounds  and polycyclic
aromatic  compounds (PACs) are the four PBT
chemical   categories    with   lower   reporting
thresholds.  The  17 members of the dioxin and
dioxin-like  compounds  category  and the  21
members of the PACs category are listed in Table
He of these instructions. The dioxin and dioxin-
like  compounds   category  has  the  qualifier,
"Manufacturing; and the processing or otherwise
use of dioxin and dioxin-like  compounds if the
dioxin and dioxin-like compounds are present as
contaminants  in a  chemical  and if  they  were
created   during  the   manufacturing   of   that
chemical."

EPA has added six individual chemicals to the
EPCRA Section 313 list of toxic chemicals that
also had their thresholds lowered:
benzo(g,h,i)perylene, benzo(j ,k)fluorene
(fluoranthene), 3 -methylcholanthrene,
octachlorostyrene, pentachlorobenzene, and
tetrabromobisphenol A (TBBPA).
Benzo(j,k)fluorene and 3-methylcholanthrene
were added as members of the polycyclic aromatic
compounds (PACs) chemical category.

EPA lowered  the  reporting thresholds for PBT
chemicals to either 100 pounds, 10 pounds, or in
the case of the dioxin and dioxin-like compounds
chemical category, to 0.1 grams.  The table at the
beginning of Section B.4 of these instructions lists
the applicable manufacture, process, and otherwise
use thresholds for the listed PBT chemicals.
                              EPA eliminated the de minimis exemption for all
                              PBT chemicals (except lead when contained in
                              stainless steel, brass or bronze alloy). However,
                              this action does not affect the applicability of the
                              de  minimis exemption to the supplier  notification
                              requirements (40 CFR Section 372.45(d)(l)).  In
                              addition, PBT  chemicals are ineligible for  range
                              reporting for on-site releases and transfers off-site
                              for further waste management. This will not affect
                              the  applicability  of  range  reporting  of  the
                              maximum amount on-site  as required  by EPCRA
                              Section 313(g).

                              All   releases  and  other  waste  management
                              quantities  greater than 0.1  pounds  of  a PBT
                              chemical  (except the dioxin  and  dioxin like
                              compounds chemical category) should  be reported
                              at a level of precision supported by the  accuracy of
                              the underlying data and estimation techniques on
                              which the estimate is based. If a facility's release
                              or  other  waste  management estimates  support
                              reporting  an amount that is more precise than
                              whole numbers,  then the  more precise  amount
                              should be reported.

                              For  the   dioxin  and  dioxin-like   compounds
                              chemical category, which has a reporting threshold
                              of 0.1 grams, facilities need only report all release
                              and other waste management  quantities greater
                              than   100  micrograms   (i.e.,   0.0001  grams).
                              Notwithstanding the numeric precision used when
                              determining   reporting   eligibility   thresholds,
                              facilities should report on the Form R  to the level
                              of accuracy that their data supports, up to  seven
                              digits to the right of the decimal. EPA's reporting
                              software and data management systems  support
                              data precision to seven digits to the right of the
                              decimal.  If  a facility has information  on  the
                              individual members of the dioxin and dioxin-like
                              compounds category they  will also need to file a
                              Form R Schedule 1 (see instructions in  Section  D).

                              Lead and Lead Compounds

                              Beginning  January  1,  2001,  lead   and lead
                              compounds are  classified  as PBT chemicals and
                              are subject to the lower manufacturing, processing
                              and  otherwise  use  threshold  of  100 pounds.
                              However, when lead is contained in stainless steel,
                              brass, or bronze  alloys it remains subject to  the
                              higher   25,000   pound    manufacturing   and
                              processing  thresholds  and the  10,000  pound
                              otherwise use threshold.  Listed below are  some
                              important  guidelines  to  use   when  calculating
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
threshold and release and other waste management
quantities for lead and lead compounds:

        1)  quantities of lead  not contained in
stainless steel, brass or bronze alloy are applied to
both   the   100   pound  threshold  and   the
25,000/10,000 pound thresholds;

        2) quantities of lead that are contained in
stainless steel, brass or bronze alloys are only
applied  toward   the  25,000/10,000    pound
thresholds;

        3)  a facility may  take the  de  minimis
exemption for those quantities of lead in  stainless
steel, brass, or  bronze alloys  that meet the de
minimis  standard  (e.g.,   manufactured  as  an
impurity). Accordingly, the de minimis exemption
may  be considered  for  quantities  of  lead in
stainless steel, brass, or bronze alloys but it may
not be considered for  lead not in stainless steel,
brass, or bronze alloys;

        4)  If  a  facility  exceeds the  100-pound
threshold for  lead other than  in  stainless steel,
brass, or bronze  alloys, the  facility may not apply
Form A eligibility for  non-PBTs, range reporting
in Sections 5 and 6  of the  Form R or the  use of
whole numbers and 2  significant digits to any of
the lead they report  though they may be eligible
for Form A using the PBT  eligibility criteria. If a
facility that  exceeds  the  25,000/10,000  pound
threshold  for  lead  in stainless steel, brass, or
bronze  alloy  without  tripping  the   100-pound
threshold for non-alloyed lead, the facility may
consider the Form A requirements for non-PBTs,
range reporting in Sections 5 and 6 of the  Form R,
and the use of whole  numbers and 2 significant
digits.

B.3.c.   Activity Exemptions

Otherwise  Use  Exemptions.  Certain otherwise
uses of listed EPCRA  Section 313  chemicals  are
specifically exempted:

•   Otherwise use as a  structural component of the
    facility;

•   Otherwise use in routine janitorial or facility
    grounds maintenance;

•   Personal uses by employees or other persons;

•   Otherwise use of products containing EPCRA
    Section  313  chemicals  for the  purpose of
    maintaining motor vehicles operated by  the
    facility; and

•   Otherwise  use   of   EPCRA  Section  313
    chemicals contained in intake water (used for
    processing or non contact cooling) or in intake
    air  (used either  as  compressed air or  for
    combustion).

The  exemption  of  an  EPCRA  Section  313
chemical  otherwise  used  1)  as  a  structural
component  of the  facility;  or  2)  in  routine
janitorial or facility grounds maintenance; or 3) for
personal use  by an employee cannot be taken for
activities involving process related equipment.

Articles  Exemption.   EPCRA   Section   313
chemicals contained  in articles that are processed
or otherwise used at  a covered facility are exempt
from  threshold  determinations  and release  and
other  waste   management   calculations.   The
exemption applies when the  facility receives  the
article from another facility or when the facility
produces the article itself. The exemption applies
only  to  the  quantity of EPCRA  Section  313
chemical  present  in  the  article. If the  EPCRA
Section 313 chemical is  manufactured (including
imported), processed,  or otherwise used  at  the
covered facility other than as part of the article, in
excess of an applicable  threshold quantity,  the
facility is required to report that use of a chemical
(40  CFR Section372.38(b)).  For  an  EPCRA
Section 313 chemical in  an item to be exempt as
part of the article, the  item  must meet all  the
following criteria in the  EPCRA  Section  313
article  definition;  that   is,  it   must   be  a
manufactured item  (1)  which  is  formed  to a
specific shape or design during manufacture,  (2)
which has end use functions dependent in whole or
in part upon its shape or design during end  use,
and (3) which does  not  release a toxic chemical
under normal conditions of processing or use  of
the item at the facility.

If the processing or otherwise use of all like items
results in a total release of 0.5 pound or less of an
EPCRA Section 313 chemical in a reporting year
to any environmental medium, EPA will allow this
release   to   be   rounded  to  zero,   and   the
manufactured items retain their article status.  The
0.5 pound  threshold  does  not  apply  to  each
individual article, but applies to the sum of all
releases from processing  or otherwise use of all
like articles. If all the releases of like articles over
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a  reporting year  are  completely  captured  and
recycled/reused  on-site or  off-site, those items
retain  their article status.  Any  amount  that  is
released  and  is not  recycled/reused will count
toward the 0.5 pound per year cut off value.

The  articles exemption applies  to the  normal
processing or use of articles. This exemption does
not  apply to  the  manufacture  of the  article.
EPCRA Section 313 chemicals incorporated into
articles produced at a facility must be factored into
threshold  determinations  and release  and  other
waste management calculations.

If, in the course of processing or use, an item
retains its initial thickness or diameter, in whole or
in part, it meets the first part (i.e., it  must be a
manufactured  item  which is formed to  a  specific
shape or design during manufacture) of the article
definition.   If the  item's  basic  dimensional
characteristics are totally altered during processing
or otherwise use, the item does not meet the first
part of the definition. An example of items that do
not meet  the  definition would be items that are
                              cold  extruded,  such  as lead ingots,  which  are
                              formed into wire or  rods. On the other hand,
                              cutting a manufactured item into  pieces that  are
                              recognizable as the article would  not change  the
                              original dimensions as long as the  diameter or the
                              thickness of the  item remained  the  same;  the
                              articles exemption would continue  to apply. Metal
                              wire  may be  bent and sheet  metal may be cut,
                              punched, stamped, or pressed without losing their
                              article status as long as the diameter of the wire or
                              tubing or the thickness of the sheet is not totally
                              changed.

                              What constitutes a release of an EPCRA Section
                              313  chemical  is  important since  processing  or
                              otherwise use of articles that result in a release to
                              the environment (or more than 0.5  pounds) negate
                              the article status and precludes eligibility for  the
                              exemption.  Cutting,  grinding,  melting,  or  other
                              processing of manufactured items could result in a
                              release of an EPCRA Section 313 chemical during
                              normal conditions of processing or otherwise  use
                              and therefore negate the exemption as articles.
 Example 4: Articles Exemption

     Q  Nickel  that is incorporated  into a  brass  doorknob is processed to manufacture the brass
         doorknob, and therefore must be counted toward threshold determinations and release and other
         waste management calculations. However, the use of the  brass doorknobs elsewhere in the
         facility does not have to be counted.  Disposal of the brass doorknob after its use does not
         constitute a "release;" thus, the brass  doorknob remains an article.
     Q  If an item used in the facility is fragmented, the item is still an article if those fragments being
         discarded remain identifiable as the  article (e.g.,  recognizable pieces of a cylinder, pieces of
         wire). For instance, an eight-foot piece of wire is cut into two four-foot pieces of wire, without
         releasing any  EPCRA  Section 313 chemicals. Each four-foot piece is identifiable as a piece of
         wire; therefore, the article status  for these pieces of wire remains intact.
     Q  EPCRA Section 313 chemicals received in the form of pellets are not articles because the pellet
         form is simply a convenient form for further processing of the material.
De  Minimis  Exemption.  The  de  minimis
exemption allows facilities to disregard certain
minimal concentrations of non-PBT chemicals
in mixtures or other trade name products when
making threshold determinations and release and
other waste management calculations. The de
minimis  exemption does  not  apply  to  the
manufacture of an EPCRA Section 313 chemical
except if that EPCRA  Section  313  chemical is
manufactured as an impurity and remains in the
product  distributed  in commerce,  or if the
                                EPCRA Section 313 chemical is imported below
                                the appropriate de minimis level. The de minimis
                                exemption does  not  apply  to  a byproduct
                                manufactured  coincidentally  as  a  result  of
                                manufacturing, processing, otherwise use, or any
                                waste management activities. The  de minimis
                                exemption does not apply to any PBT  chemical
                                (except lead  when  it is contained  in  stainless
                                steel, brass or bronze  alloy) or PBT  chemical
                                category. A list of PBT chemicals may be found
                                in Section B.4 of these instructions.
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
When  determining whether  the de  minimis
exemption  applies to  an EPCRA Section 313
chemical, the owner/operator must consider the
concentration of the non-PBT EPCRA Section
313 chemical in mixtures and other trade name
products. If the non-PBT EPCRA Section 313
chemical in  a mixture or other trade  name
product  is  manufactured   as  an  impurity,
imported, processed, or otherwise used  and  is
below the appropriate  de minimis concentration
level, then the quantity of the non-PBT EPCRA
Section 313 chemical in that mixture or other
trade name  product does not have to be applied
to threshold determinations  nor included  in
release   or   other   waste    management
determinations. If a non-PBT  EPCRA Section
313 chemical in a mixture or other trade name
product is  below  the  appropriate  de minimis
level, all releases and other waste management
activities associated with the  EPCRA Section
313 chemical in that mixture or other trade name
product are exempt from EPCRA Section 313
reporting. It is possible to meet an activity (e.g.,
processing)  threshold  for  an EPCRA  Section
313 chemical on a facility wide basis, but not be
required  to calculate  releases or other waste
management  quantities  associated   with  a
particular process because that process involves
only mixtures  or other trade name  products
containing  the  non-PBT EPCRA Section 313
chemical below the de  minimis level.

EPA interprets the de minimis exemption such
that  once  a  non-PBT EPCRA  Section  313
chemical concentration is at  or above the
appropriate de minimis level in the mixture  or
other   trade   name    product    threshold
determinations  and  release and  other waste
management calculations must be made, even if
that  chemical later falls below the de minimis
level in the same mixture or other trade name
product.  Thus,  EPA considers reportable  all
releases and other quantities managed as waste
that  occur  after the de minimis level has been
met  or exceeded.  If an  EPCRA  Section  313
chemical in  a  mixture or  other trade name
product at  or above  de minimis is brought on-
site,  the de minimis exemption never applies.

De minimis levels for non-PBT EPCRA Section
313 chemicals and chemical categories are set at
concentration levels  of either 1 percent or 0.1
percent; PBT chemicals and chemical categories
do not  have de minimis levels with regard to this
exemption.  The 0.1 percent de minimis levels are
dictated by  determinations made by the National
Toxicology Program (NTP) in its Annual Report
on Carcinogens, the International Agency for
Research and Cancer (IARC) in its Monographs,
or 29 CFR part 1910, subpart Z. Therefore, once
a non-PBT  chemical's status under NTP, IARC,
or 29 CFR part 1910, subpart Z indicates that the
chemical is  a carcinogen or potential carcinogen,
the reporting facility may disregard levels of the
chemical below the  0.1  percent de minimis
concentration provided that the other criteria for
the de  minimis exemption  are met. De minimis
levels for chemical categories apply to the total
concentration of all  chemicals in  the category
within  a mixture, not the concentration  of each
individual category member within the mixture.
                   Toxics Release Inventory Reporting Forms and Instructions
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 Example  5:  De Minimis Applications to  Process  and  Otherwise  Use Scenarios for Non-PBT
 Chemicals

 There are many cases in which the de minimis "limit" is crossed or recrossed by non-PBT chemicals
 within a process or otherwise use scenario. The following examples are meant to illustrate these complex
 reporting scenarios.

 Increasing Concentration To or Above  De  Minimis  Levels During Processing for Non-PBT
 Chemicals

 A manufacturing facility receives toluene that contains chlorobenzene at  a concentration below its de
 minimis limit. Through distillation, the chlorobenzene content in process streams is increased over the de
 minimis concentration of 1 percent. From the point at which the chlorobenzene concentration equals 1
 percent in process streams, the amount present must be factored into threshold determinations and release
 and  other waste  management  estimates.  The  facility does  not  need  to consider the  amount of
 chlorobenzene in the raw material when below de minimis levels, i.e., prior to distillation to 1  percent,
 when making threshold determinations. The facility does not have to report emissions of chlorobenzene
 from storage tanks or any other equipment associated with that specific process where the chlorobenzene
 content is  less than 1 percent.

 Fluctuating Concentration During Processing for Non-PBT Chemicals

 A manufacturer produces an ink product that contains toluene, an EPCRA  Section 313 chemical, below
 the de minimis level. The process used causes the percentage of toluene in the mixture to fluctuate: it rises
 above the de minimis level for a time but drops below the level as the process winds down. The facility
 must consider the chemical toward threshold determinations from the point  at which it first equals the de
 minimis limit. Once the de minimis limit has been met the exemption cannot  be taken.
De Minimis Application to the Processing or
Otherwise Use of a Mixture
                               Concentration  Ranges  Straddling  the  De
                               Minimis Value
The  de  minimis  exemption  applies  to the
processing  or  otherwise  use  of  a  non-PBT
EPCRA  Section  313 chemical in a  mixture.
Threshold determinations and release and other
waste  management calculations  begin  at the
point where the chemical meets or exceeds the
de minimis level. If a non-PBT EPCRA Section
313  chemical is present in a  mixture at  a
concentration below the de minimis level, this
quantity of the substance  does not have to be
included  for threshold determinations, release
and  other  waste  management  reporting,  or
supplier    notification    requirements.    The
exemption  will apply as  long as the mixture
containing  de minimis amounts of a non-PBT
EPCRA Section 313 chemical never equals or
goes above the de minimis limit.
                               There   may   be  instances   in   which  the
                               concentration of a non-PBT chemical is given as
                               a range straddling the de minimis limit. Example
                               6  illustrates  how the de minimis exemption
                               should be applied in such a scenario.

                               De Minimis Application in the Manufacture
                               of the Listed Chemical in a Mixture

                               The de minimis exemption generally does not
                               apply  to the  manufacturing  of  an  EPCRA
                               Section 313 chemical. However, the de minimis
                               exemption  may apply to mixtures and  other
                               trade  name   products   containing  non-PBT
                               EPCRA Section 313 chemicals that are imported
                               into the United States.  (See Example 5.)

                               The exemption also applies to non-PBT EPCRA
                               Section 313 chemicals that are  manufactured as
                               impurities that remain in the product distributed
                               in commerce below the  de minimis levels. The
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

amount remaining in the product is exempt from       an   EPCRA  Section  313  chemical  that  is
threshold  determinations.  If  the chemical  is       manufactured  in  a  waste  stream  must  be
separated  from  the  final  product,  it cannot       considered toward threshold determinations and
qualify for the exemption. Any amount that is       release    and   other   waste   management
separated, or is  separate, from  the product, is       calculations and accounted  for on Form R even
considered  a  byproduct  and  is  subject  to       if that chemical is manufactured  below the  de
threshold determinations and release  and  other       minimis level.
waste management calculations.  Any amount of
 Example 6: Concentration Ranges Straddling the De Minimis Value

 D      A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25 percent manganese.
 Manganese is eligible for the de minimis exemption at concentrations up to  1 percent. The amount of
 mixture subject to reporting  is the  quantity  containing manganese at or above the de  minimis
 concentration:

        [(8,000,000) H (1.25% - 0.99%)] ) (1.25% + 0.25%)

 The average concentration of manganese that is not exempt (above the de minimis} is:
        (1.25%+1.00%)) (2)
  '(8,000,000X1.25%-0.99%)'
                                x
                                 '(l.25%+ 1.00%)'
                                                   = 23,400pounds
         (l.25%-0.25%)
 Therefore, the amount of manganese that is subject to threshold determination and release and other waste
 management estimates is:

        = 23,400 pounds manganese (which is below the processing threshold for manganese)

 In this scenario, because the facility's information pertaining to manganese was available to two decimal
 places, 0.99 was used to determine the amount below the de minimis concentrations. If the information
 was available to one decimal place, 0.9 should be used, as in the scenario below.

 D      As in the previous example, manganese  is present in a mixture, of which 8,000,000 pounds is
 processed. The MSDS states the mixture contains 0.2 percent to 1.2 percent manganese. The amount of
 mixture subject to reporting (at or above de minimis limit) is:

        [(8,000,000) H (1.2% - 0.9%)] ) (1.2% - 0.2%)

 The average concentration of manganese that is not exempt (at or above de minimis limit) is:

        (1.2%+1.0%)) (2)

 Therefore, the  amount  of manganese that is  subject to threshold determinations and release and other
 waste management estimates is:
                                               = 26,400 pounds
 '(8,000,OOOXl.2% - 0.9%)1  I"(l.2% + 1.0%)'
        (l.2%-0.2%)      ][     (2)
= 26,400 pounds manganese (which is above the processing threshold for manganese)
                   Toxics Release Inventory Reporting Forms and Instructions                    19

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 Example 7: De Minimis Application in the Manufacture of a Toxic Chemical in a Mixture

 Manufacture as a Product Impurity

 Toluene  2,4  diisocyanate  reacts  with  trace  amounts  of water  to  form  trace  quantities  of 2,4-
 diaminotoluene. The resulting product contains 99 percent toluene 2,4-diisocyanate and 0.05 percent 2,4-
 diaminotoluene. The 2,4 diaminotoluene would not be  subject  to EPCRA  Section 313  reporting  nor
 would supplier  notification be required because the concentration of 2,4- diaminotoluene is below its de
 minimis limit of 0.1 percent in the product.

 Manufacture as a Commercial Byproduct and Impurity

 Chloroform is a reaction byproduct in the production of carbon tetrachloride. It is removed by distillation
 to a concentration of less than 150 ppm (0.0150 percent) remaining in the  carbon tetrachloride. The
 separated chloroform at 90 percent concentration  is sold  as a byproduct. Chloroform is  subject to a 0.1
 percent (1000  ppm) de  minimis limit.  Any amount of chloroform manufactured and separated as
 byproduct must be included in threshold determinations because  EPA does not interpret the de minimis
 exemption to apply to the manufacture of a chemical as a  byproduct. Releases of chloroform prior to  and
 during purification of the carbon tetrachloride must be reported. The de minimis exemption can, however,
 be  applied to  the chloroform remaining in the carbon tetrachloride as an impurity.  Because  the
 concentration of chloroform remaining  in the carbon tetrachloride is below the  de minimis limit,  this
 quantity of chloroform is exempt from threshold determinations, release and other  waste management
 reporting, and supplier notification.

 Manufacture as a Waste Byproduct

 A small amount  of formaldehyde is manufactured as a reaction byproduct during the production of
 phthalic anhydride. The formaldehyde is separated from the phthalic anhydride as a waste gas and burned,
 leaving no  formaldehyde in the phthalic anhydride. The amount of formaldehyde produced and removed
 must be included in threshold determinations and  release  and other waste management estimates even if
 the formaldehyde were present  below  the  de  minimis level  in the  process  stream where it was
 manufactured or in the waste stream to which it was separated because EPA does not interpret mixtures
 and trade name  products to includes wastes.	
The de minimis exemption also does not apply to
situations  where  a toxic chemical in waste  is
diluted to below the de minimis level.

Laboratory   Activities   Exemption.  EPCRA
Section 313  chemicals  that  are  manufactured,
processed, or otherwise used in a laboratory at a
covered facility under the direct supervision of a
technically qualified individual do not have to  be
considered  for   threshold  determinations  and
release and other  waste management calculations.
However,  pilot plant scale and specialty chemical
production does  not qualify for this  laboratory
activities exemption, nor  does the use  of EPCRA
Section 313   chemicals  for laboratory  support
activities,  such  as the  use  of chemicals  for
equipment maintenance.
                              Coal  Extraction Activities  Exemption. If an
                              EPCRA Section 313  chemical is manufactured,
                              processed,  or otherwise  used  in  extraction by
                              facilities  in NAICS codes  212111, 212112 and
                              212113, a person is not required to consider the
                              quantity of the  EPCRA Section 313 chemical so
                              manufactured, processed,  or otherwise  used when
                              considering threshold  determinations and release
                              and other  waste  management  calculations  (see
                              Example   8).  Reclamation  activities  occurring
                              simultaneously with coal extraction activities (e.g.,
                              cast  blasting)  are included  in the  exemption.
                              However,  otherwise use  of ash, waste rock, or
                              fertilizer   for  reclamation  purposes   are  not
                              considered part of extraction; non-exempt amounts
                              of EPCRA Section 313  chemicals  contained in
                              these   materials  must  be  considered  toward
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
threshold  determinations  and release  and other
waste management calculations.

Metal Mining Overburden  Exemption.  If an
EPCRA Section 313 chemical that is a constituent
of overburden is processed or otherwise used by
facilities   in  NAICS  codes 212221,  212222,
212231, 212234,  and  212299,  a person is  not
required to consider  the quantity of the EPCRA
Section 313 chemical so  processed  or otherwise
used when considering threshold determinations
and   release   and   other  waste   management
calculations.

For purposes of EPCRA  Section 313 reporting,
overburden is the unconsolidated  material  that
overlies a deposit of useful material or ore. It does
not include any portion of the ore or waste rock.
 Example 8: Coal mining extraction activities

 Included  among these  are  explosives  for
 blasting operations, solvents, lubricants,  and
 fuels   for   extraction   related   equipment
 maintenance  and use, as well as overburden
 and mineral deposits. The EPCRA Section 313
 chemicals  contained  in  these  materials  are
 exempt from threshold  determinations  and
 release   and   other   waste   management
 calculations, when manufactured, processed or
 otherwise  used during extraction  activities at
 coal mines.
B.4   Threshold Determinations
EPCRA  Section  313  reporting is  required if
threshold   quantities  are  exceeded.  Separate
thresholds apply to the amount of the EPCRA
Section  313  chemical  that  is  manufactured,
processed or otherwise used.

You must submit a report for any EPCRA Section
313 chemical that is not listed as a PBT chemical
and which  is manufactured or processed at your
facility in excess of the following threshold:

•   25,000 pounds per toxic chemical or category
    over the calendar year.

•   You  must submit a  report for  any EPCRA
    Section 313 chemical which is not listed as a
    PBT  chemical and that is otherwise used at
    your  facility in  excess of 10,000 pounds per
    toxic chemical or category over the calendar
    year.

You must submit a report for any EPCRA Section
313 chemical that is listed as a PBT chemical and
which  is manufactured, processed or otherwise
used  at your facility above the  designated
threshold for that chemical.

The PBT chemical names, CAS numbers and their
reporting thresholds are listed in the table below.
See Table  He of these instructions for lists of
individual members of the dioxin and dioxin-like
compounds chemical category and the polycyclic
aromatic compounds chemical category.
                   Toxics Release Inventory Reporting Forms and Instructions
                                           21

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Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds category
(manufacturing; and
the processing or
otherwise use of dioxin
and dioxin-like
compounds category if
the dioxin and dioxin-
like compounds are
present as
contaminants in a
chemical and if they
were created during
the manufacturing of
that chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead (this lower
threshold does not
apply to lead when it is
contained in stainless
steel, brass or bronze
alloy)
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Fob/chlorinated
biphenyls (PCBs)
Poly cyclic aromatic
compounds category
(PACs)
Tetrabromobisphenol
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439.97-6
N458
72-43-5
29082-74-4
40487-42-1
608-93-5
1336-36-3
N590
79-94-7
Threshold
(pounds,
unless
noted
otherwise)
100
10
10
0. 1 gram
10
10
10
100
100
10
10
100
10
100
10
10
100
100
A
Toxaphene
Trifluralin

8001-35-2
1582-09-8

10
100
                                                B.4.a.   How to Determine if Your
                                                         Facility Has Exceeded
                                                         Thresholds

                                                To determine whether your facility has exceeded
                                                an  EPCRA  Section  313  reporting  threshold,
                                                compare  quantities  of  EPCRA  Section  313
                                                chemicals  that  you  manufacture,  process,  or
                                                otherwise use to the respective thresholds for those
                                                activities. A worksheet is provided in Figure 2A to
                                                assist facilities in determining whether they exceed
                                                any of  the  reporting  thresholds  for  non-PBT
                                                chemicals; Figures 2B-D provide worksheets for
                                                PBT chemicals.  This worksheet also provides  a
                                                format for maintaining reporting facility records.
                                                Use of this worksheet is not required and the
                                                completed worksheet(s)  should  not  accompany
                                                Form R reports submitted to EPA and the state.

                                                Complete  the  appropriate worksheet  for  each
                                                EPCRA   Section  313  chemical  or  chemical
                                                category. (The worksheets can be found at the end
                                                of section B.4.) Base your threshold determination
                                                for EPCRA Section 313 chemicals with qualifiers
                                                only on  the quantity of the  EPCRA Section 313
                                                chemical satisfying the qualifier.

                                                Use of the worksheets is divided into three steps:

                                                •  Step 1 allows you to record the gross amount
                                                   of the  EPCRA Section  313 chemical  or
                                                   chemical  category  involved  in  activities
                                                   throughout the facility. Pure forms as well as
                                                   the  amounts  of the  EPCRA Section  313
                                                   chemical  or  chemical  category  present in
                                                   mixtures or other trade name products must be
                                                   considered.  The  types  of  activity  (i.e.,
                                                   manufacturing,   processing,   or   otherwise
                                                   using) for  which  the EPCRA  Section  313
                                                   chemical is used must be identified because
                                                   separate thresholds apply to each of these
                                                   activities.  A  record  of  the  information
                                                   source(s)  used  should   be   kept.  Possible
                                                   information sources include purchase records,
                                                   inventory data, and calculations by  a process
                                                   engineer. The data  collected in Step 1  will be
                                                   totaled for each activity to identify the overall
                                                   amount of the EPCRA Section 313 chemical
                                                   or chemical category manufactured (including
                                                   imported), processed, or otherwise used.
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
•   Step  2 allows you  to  identify uses of the
    EPCRA Section  313 chemical or chemical
    category that were included in Step 1 but are
    exempt under EPCRA  Section 313.  Do not
    include in Step 2  exempt  quantities of the
    EPCRA Section 313 chemical not included in
    the calculations in Step  1. For example, if
    Freon  contained   in  the  building's  air
    conditioners was not  reported in Step 1, you
    would not include the amount  as  exempt in
    Step  2. Step  2  is intended for use when  a
    quantity or use  of the  EPCRA Section 313
    chemical  is  exempt  while  other  quantities
    require reporting. Note the type of exemption
    for   future  reference.    Also   identify,  if
    applicable, the fraction  or percentage of the
    EPCRA Section 313  chemical present that is
    exempt. Add the amounts in each activity to
    obtain a subtotal for exempted amounts of the
    EPCRA Section  313 chemical or chemical
    categories at the facility.

•   Step 3 involves subtracting the result of Step 2
    from the results of Step  1  for  each activity.
    Compare  this  net  sum  to the  applicable
    activity threshold. If the threshold is exceeded
    for any of the three activities, a facility must
    submit a Form R for that EPCRA Section 313
    chemical or chemical category. Do not sum
    quantities of the EPCRA Section 313 chemical
    that   are   manufactured,  processed,  and
    otherwise used at your facility, because each
    of these activities requires a separate threshold
    determination. For example, if in  a calendar
    year you processed 20,000 pounds  of a non-
    PBT  EPCRA  Section 313 chemical and you
    otherwise used  6,000 pounds  of that  same
    chemical, your facility has not  exceeded any
    applicable threshold and thus is not required to
    report for that chemical.

Worksheets should be retained to document your
determination for reporting  or not  reporting, but
should not be submitted with the report.

You must submit a report if you exceed any
threshold for any EPCRA Section 313 chemical or
chemical category. For example, if your facility
processes  22,000  pounds of a non-PBT EPCRA
Section  313 chemical  and also otherwise uses
16,000 pounds of that  same  chemical, it has
exceeded  the  otherwise  use threshold (10,000
pounds for a non-PBT chemical) and your facility
must  report even though it did not exceed the
process threshold (25,000 pounds  for a non-PBT
chemical). In preparing your reports, you  must
consider  all  non-exempted  activities  and  all
releases and other waste management quantities of
the EPCRA  Section  313  chemical  from  your
facility,  not  just  releases  and  other  waste
management  quantities from the  otherwise use
activity.

Also note that threshold determinations are based
upon the actual  amounts of an EPCRA Section
313   chemical   manufactured,  processed,  or
otherwise used  over the  course of the  calendar
year. The threshold determination  may not relate
to the amount of an EPCRA Section 313 chemical
brought  on-site  during  the calendar year.  For
example, if a stockpile of  100,000 pounds of a
non-PBT EPCRA Section 313 chemical is present
on-site but only 20,000 pounds of that chemical is
applied to  a process,  only the  20,000 pounds
processed  is  counted  toward   a   threshold
determination, not the entire  100,000 pounds of
the stockpile.

B.4.b.  Threshold Determinations for
         On-Site Reuse  Operations

Threshold determinations  of EPCRA Section 313
chemicals that are reused  at the facility are based
only on the  amount of the  EPCRA Section 313
chemical that is added during the year, not the
total volume in the system. For example, a facility
operates  a refrigeration unit that contains 15,000
pounds of anhydrous ammonia at the beginning of
the year.  The system is charged with 2,000 pounds
of anhydrous ammonia  during  the  year.  The
facility has therefore "otherwise used" only 2,000
pounds  of  anhydrous  ammonia,  a  non-PBT
EPCRA Section 313 chemical, which is below the
otherwise use threshold for anhydrous ammonia
and is not required to report  (unless there are other
"otherwise use" activities of ammonia, that when
taken together, exceed the reporting threshold). If,
however,  the  whole  refrigeration   unit   was
recharged with   15,000  pounds  of  anhydrous
ammonia during the year, then the facility would
have exceeded the otherwise use  threshold, and
would be required to report.

This does  not   apply  to  EPCRA Section  313
chemicals "recycled"  or "reused"  off-site  and
returned  to  a facility.  Such EPCRA Section 313
chemicals returned to a facility are treated  as the
equivalent  of  newly  purchased  material  for
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purposes  of  EPCRA  Section  313  threshold
determinations.

B.4.c.   Threshold Determinations for
         Ammonia

The  listing  for ammonia  includes the modifier
"includes   anhydrous  ammonia  and   aqueous
ammonia from water dissociable ammonium salts
and  other sources;  10 percent of total  aqueous
ammonia  is reportable under this  listing." The
qualifier for ammonia means that anhydrous forms
of ammonia are  100  percent  reportable and
aqueous forms are limited to  10  percent of total
aqueous ammonia. Therefore, when determining
threshold  quantities, 100  percent of  anhydrous
ammonia is included but only 10 percent of total
aqueous ammonia is included. If any ammonia
evaporates from aqueous ammonia solutions, 100
percent of the evaporated ammonia is included in
threshold determinations.

For  example,  if a  facility processes  aqueous
ammonia,  it has  processed  100  percent of the
aqueous ammonia in that solution. If the ammonia
remains in solution, then 10 percent of the total
aqueous   ammonia  is  counted   towards  the
threshold.  If there are any evaporative losses  of
anhydrous ammonia, then 100 percent of those
losses must be counted towards the processing
threshold.  If the  manufacturing, processing,  or
otherwise use threshold for the ammonia listing is
exceeded,  the facility must report 100  percent of
these evaporative losses in Sections 5 and 8 of the
Form R.

B.4.d.   Threshold Determinations for
         Chemical Categories

A number of chemical compound categories are
subject to  reporting. See Table He for a listing of
these EPCRA Section 313 chemical categories.
When preparing threshold determinations for one
of these EPCRA Section 313 chemical categories,
all individual  members of a category that are
manufactured, processed, or otherwise  used must
be counted.  Where  generic names are used at a
facility,  threshold  determinations should be based
on CAS numbers.  For  example,  Poly-Solv  EB
does not appear among the reportable chemicals in
Table Ha  or lib  but its CAS number indicates
Poly-Solv EB  is a synonym for  ethylene glycol
mono-n-butyl  ether, a member  of the  certain
glycol ethers chemical category (code N230). For
chemical   compound    categories,   threshold
determinations must be made separately for each
                             of the three  activities. Do not include  in these
                             threshold  determinations  for  a  category  any
                             chemicals that are also individually listed EPCRA
                             Section 313  chemicals  (see  Table  Ha  or lib).
                             Individually listed EPCRA Section 313 chemicals
                             are  subject to their own individual threshold
                             determination.

                             Organic Compounds

                             For  the organic compound categories,  you are
                             required to account  for the entire weight of all
                             compounds within a specific compound  category
                             (e.g., glycol ethers) at the facility for BOTH the
                             threshold  determination  and release  and other
                             waste management estimates.

                             Metal Category Compounds

                             Threshold  determinations  for metal   category
                             compounds present a special case. If, for example,
                             your facility processes  several different  nickel
                             compounds, base your threshold determination on
                             the  total  weight  of  all  nickel   compounds
                             processed.  However,  if  your facility processes
                             both the "parent" metal (nickel) as well as one or
                             more nickel compounds, you must make threshold
                             determinations  for both  nickel  (CAS  number
                             7440-02-0)  and  nickel   compounds  (chemical
                             category code N495) because they are separately
                             listed EPCRA  Section  313 chemicals.  If your
                             facility  exceeds thresholds for both the  parent
                             metal and compounds of that same metal, EPA
                             allows you to file one combined report (e.g., one
                             report for  nickel compounds, including nickel)
                             because the release information you will report in
                             connection with metal category compounds will be
                             the total pounds of the metal released. If you file
                             one  combined report, you should put the  name of
                             the metal  compound category on the  Form R. In
                             the  example above, the  facility  that exceeded
                             reporting thresholds for both the nickel and nickel
                             compounds  chemical category could submit  a
                             single Form R for the nickel compounds chemical
                             category, which would contain release and other
                             waste management information for both nickel and
                             nickel compounds. Do not put both names on the
                             Form R.

                             The case of metal category compounds involving
                             more than one metal should be noted. Some metal
                             category compounds may  contain  more than one
                             listed metal. For example, lead chromate is both a
                             lead compound and a chromium compound. In
                             such cases, if applicable thresholds are exceeded,
                             you are required to file two separate reports, one
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         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A
for lead  compounds  and one  for  chromium
compounds.  Apply the total weight of the lead
chromate to the threshold determinations for both
lead  compounds  and  chromium  compounds.
(Note:  Only the quantity of each parent metal
released or otherwise managed as waste, not the
quantity of the  compound, would be reported on
the appropriate sections  of both Form Rs.  See
B.5.)

Nitrate   Compounds   (water   dissociable;
reportable only when in aqueous solution)

For  the  category  nitrate  compounds  (water
dissociable;  reportable only  when in aqueous
solution),  the  entire  weight  of the   nitrate
compound  is  counted  in   making  threshold
determinations.  A nitrate compound is covered by
this  listing  only when  in  water  and  only if
dissociated. If no information is available on the
identity of the type of nitrate that is manufactured,
processed or otherwise  used, assume that the
nitrate compound exists as sodium nitrate.

B.4.e    Threshold Determination for
         Persistent Bioaccumulative
         Toxic (PBT) Chemicals

There  are two  separate  thresholds for EPCRA
Section 313  PBT chemicals;  these thresholds are
set based on the chemicals' potential to persist and
bioaccumulate   in    the   environment.   The
manufacturing,  processing and  otherwise  use
thresholds for PBT chemicals is 100 pounds, while
for the subset of PBTs chemicals that  are highly
persistent  and  highly bioaccumulative, it is 10
pounds. One exception is the dioxin and  dioxin-
like compounds chemical category.  The threshold
for this category is 0.1 gram. The PBT  chemicals,
their CAS numbers or chemical category code, and
their reporting thresholds are listed in a table in the
introductory section of B.4. See Table He of these
instructions for  lists of individual members of the
dioxin   and  dioxin-like   compounds  chemical
category and the polycyclic aromatic compounds
(PACs) chemical category.

B.4.f.   Mixtures and Other Trade
         Name Products

EPCRA  Section  313  chemicals  contained  in
mixtures and other trade  name products must be
factored into threshold determinations and  release
and other waste  management calculations.
If your  facility  processed  or otherwise  used
mixtures  or other trade name products during the
calendar  year, you are required to use the best
readily available data (or reasonable estimates if
such data are not readily available) to determine
whether the toxic chemicals in a mixture meet or
exceed   the  de   minimis   concentration  and,
therefore, whether  they  must be  included  in
threshold  determinations  and  release and other
waste management calculations. If you know that
a mixture or other trade name product contains a
specific EPCRA Section  313  chemical, combine
the amount of the EPCRA Section 313 chemical in
the mixture or other trade name product with other
amounts   of  the  same  EPCRA  Section 313
chemical  processed  or otherwise used  at your
facility for threshold determinations and  release
and other waste management calculations. If you
know that a mixture  contains an EPCRA Section
313  chemical but it is  present  below the  de
minimis level, you do  not have to consider the
amount of the  EPCRA  Section  313  chemical
present in that mixture for purposes of threshold
determinations  and  release  and  other  waste
management calculations. PBT chemicals are not
eligible for the de minimis exemption except lead
when it is contained in stainless  steel, brass  or
bronze alloy.

Observe  the  following guidelines  in estimating
concentrations of EPCRA Section 313 chemicals
in mixtures  when only  limited  information  is
available:

•   If  you  only   know  the   upper  bound
    concentration, you  must use it for threshold
    determinations (40 CFR Section372.30(b)(ii)).

•   If  you know  the  lower  and  upper bound
    concentrations of an EPCRA Section 313
    chemical  in a mixture, EPA recommends you
    use the midpoint of these  two concentrations
    for threshold determinations.

•   If  you  know  only  the   lower  bound
    concentration, EPA recommends you subtract
    out  the  percentages  of  any  other  known
    components to determine  a reasonable upper
    bound concentration,  and  then  determine a
    midpoint.

•   If you have  no  information other  than the
    lower bound concentration, EPA recommends
                   Toxics Release Inventory Reporting Forms and Instructions
                                          25

-------
    you calculate a midpoint assuming an upper
    bound concentration of 100 percent.

•   In cases where you only have a concentration
    range available, EPA recommends you use the
    midpoint of the range extremes.

B.5   Release and Other  Waste
       Management Determinations
       for Metals, Metal Category
       Compounds, and Nitrate
       Compounds
Metal Category Compounds

Although  the  complete  weight  of  the  metal
category  compounds  must  be used in threshold
determinations  for the metal compounds category,
only the weight of the metal portion of the metal
category compound must be considered for release
and  other  waste  management determinations.
Remember that for metal category compounds that
consist of more than one metal,  release and other
waste management reporting must be based on the
weight of each metal, provided that the appropriate
thresholds have been exceeded.

Metals and Metal Category Compounds

For  compounds  within  the  metal  compound
categories, only the metal  portion of the metal
category  compound  must be considered  in
determining release and other waste management
quantities  for  the  metal   category compounds.
Therefore, if thresholds are separately exceeded
                             for both the  "parent" metal and  its  compounds,
                             EPA allows you to file a combined Form R for the
                             "parent" metal and its category compounds. This
                             Form R would contain all of the release and other
                             waste  management  information  for  both  the
                             "parent" metal and  metal portion of the related
                             metal  category compounds.  For example,  you
                             exceed thresholds  for chromium. You also exceed
                             thresholds for chromium  compounds. Instead of
                             filing two Form Rs  you  can file one  combined
                             Form R. This Form  R would contain information
                             on quantities of chromium released or otherwise
                             managed  as  waste   and  the  quantities  of the
                             chromium portion of the chromium compounds
                             released  or otherwise managed as waste. When
                             filing  one combined Form  R for  an EPCRA
                             Section 313 metal and metal compound category,
                             facilities should identify the chemical reported as
                             the metal compound category name and code in
                             Section 1 of the Form R. Note that this does not
                             apply to the  Form  A. See the section in these
                             instructions on the Form A. See Appendix B for
                             more  information  about reporting  the release and
                             other  waste  management  of metals  and metal
                             compounds.

                             Nitrate Compounds (water dissociable;
                             reportable only in aqueous solution)

                             Although the complete  weight  of the nitrate
                             compound  must  be   used    for   threshold
                             determinations for the nitrate compounds category
                             only the nitrate portion of the compound should be
                             used  for  release  and other  waste  management
                             calculations.
26
Toxics Release Inventory Reporting Forms and Instructions

-------
         How to Determine if Your Facility Must Submit a Form R or Is Eligible to Use Form A

 Example 9: Mixtures and Other Trade Name Products
 Scenario #1: Your facility otherwise uses  12,000 pounds  of an industrial solvent (Solvent  X) for
 equipment cleaning. The Material Safety Data Sheet (MSDS) for the solvent indicates that it contains at
 least 50 percent n-hexane, an EPCRA Section 313 chemical;  however,  it also  states that the  solvent
 contains 20 percent non-hazardous surfactants.  This is the only  n-hexane-containing mixture used at the
 facility.
 EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
 in solvent X exceeds the threshold for otherwise use.
 1)    Determine a reasonable  maximum concentration  for the  EPCRA  Section 313  chemical by
      subtracting out the non-hazardous surfactants (i.e., 100% - 20% = 80%).
 2)    Determine the midpoint  between the known minimum  (50%) and the  reasonable  maximum
      calculated above (i.e., (80% + 50%)/2 = 65%).
 3)    Multiply total weight of Solvent X otherwise used by 65% (0.65).
      12,000 pounds x 0.65 = 7,800 pounds
 4)    Because the total amount of n-hexane otherwise used at the facility was less than the 10,000-pound
      otherwise use threshold, the facility is not required to file a Form R for n-hexane.
 Scenario #2: Your facility otherwise used 15,000 pounds of Solvent Y to clean printed circuit  boards.
 The MSDS for the solvent lists only that Solvent Y contains at least 80 percent of an EPCRA Section 313
 chemical that is only identified as chlorinated hydrocarbons.
 EPA recommends you follow these steps to determine if the quantity of the EPCRA Section 313 chemical
 in the solvent exceeds the threshold for otherwise use.
 1)    Because the specific chemical is unknown, the Form  R will be filed for "chlorinated hydrocarbons."
      This name will be entered into Part II, Section 2.1, "Mixture Component Identity." (Note: Because
      your supplier is claiming the EPCRA Section 313 chemical identity a trade secret, you do not have
      to file substantiation forms.)

 2)    The upper bound limit is assumed to be 100 percent and the lower bound limit is known to be 80
      percent. Using this information, the specific concentration is estimated to be 90 percent (i.e., the
      mid-point between upper and lower limits).
      (100% + 80%)/2 = 90%

 3)    The total weight of Solvent Y is multiplied by 90 percent (0.90) when calculating for thresholds.
       15,000x0.90 = 13,500
 4)    Because the  total amount  of chlorinated hydrocarbons exceeds the 10,000-pound otherwise use
	threshold, you must file a Form R for this chemical.	
                   Toxics Release Inventory Reporting Forms and Instructions                    27

-------














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 C.    Instructions for
        Completing TRI Form R

 Parti.  Facility Identification
          Information

 Section 1.    Reporting Year
 The reporting year is the calendar year to which
 the reported information applies, not the  year in
 which you are submitting the report. Information
 for the 2009 reporting year must be submitted on
 or before July 1,2010.

 Section 2.    Trade Secret Information
2.1     Are  you claiming the EPCRA Section
        313  chemical identified on Page 2  a
        trade secret?
 Answer  this  question  only  after  you  have
 completed the rest of the  report.  The specific
 identity of the EPCRA Section 313 chemical being
 reported in Part II, Section 1 may be designated as
 a trade secret. If you are making a trade secret
 claim,  mark "yes" and  proceed  to  Section  2.2.
 Only check "yes" if you manufacture, process, or
 otherwise use the EPCRA Section 313 chemical
 whose  identity is a trade secret. (See Section A.3
 of these  instructions  for specific information on
 trade  secrecy claims.)  If  you  checked "no,"
 proceed to Section 3; do not answer Section 2.2.

 D  See last year's Reporting Forms and
    Instructions.

2.2     If "yes" in 2.1, is this copy  sanitized or
        unsanitized?
 Answer  this  question  only  after  you  have
 completed the rest of the report. Check "sanitized"
 if this copy of the report is the public version that
 does not contain the EPCRA Section 313 chemical
 identity but  does contain a  generic name that  is
 structurally  descriptive in its place,  and if you
 have  claimed the EPCRA Section 313 chemical
 identity  trade secret in Part  I,  Section  2.1.
 Otherwise, check "unsanitized."
 Section 3.    Certification
 The certification statement must be signed  by a
 senior official with management responsibility for
 the person (or persons)  completing the form. A
                              senior  management  official  must  certify  the
                              accuracy  and completeness  of the  information
                              reported on the  form by  signing and dating the
                              certification statement. Each  report must contain
                              an original signature. You should print or type the
                              name  and title  of  the  person who  signs  the
                              statement in the  space provided. This certification
                              statement applies to  all the information supplied
                              on the form and should be signed only after the
                              form has been completed.

                              Section 4.    Facility Identification

                             4.1      Facility   Name,  Location,   and   TRI
                                     Facility  Identification Number

                              Enter the full name that the facility presents to the
                              public and its customers in doing  business (e.g.,
                              the name that appears on invoices, signs, and other
                              official  business  documents).  Do  not use a
                              nickname for the facility (e.g., Main Street Plant)
                              unless that is the legal name  of the facility under
                              which it  does  business.  Also  enter the  street
                              address, mailing address,  city, county, state, and
                              zip code in the space provided. Do not use a post
                              office box number as the street address. The street
                              address provided must be the location where the
                              EPCRA Section 313  chemicals are manufactured,
                              processed, or otherwise  used. If your  mailing
                              address and  street  address  are the  same,  you
                              should  enter NA  in the  space  for  the  mailing
                              address.

                              If your facility is not in a county, put the name of
                              your city,  district  (for  example,  District  of
                              Columbia), or parish (if you  are in Louisiana) in
                              the county block of  the Form R and  Form A as
                              well as in the county  field of TRI-ME OR  TRI-
                              MEweb.  "NA"  or  "None"  are  not acceptable
                              entries.

                              If you have submitted a Form R or  Form A for
                              previous   reporting   years,   a   TRI   Facility
                              Identification Number  has been assigned to  your
                              facility.   If   you   know  your   TRI   Facility
                              Identification  Number,  you should  complete
                              Section 4.  If you do not know your TRI Facility
                              Identification Number, you should visit the TRI
                              web                  page                  at
                              http ://www. epa. gov/tri/contacts/contacts .htm   for
                              more information  or contact  your Regional TRI
                              Program representative, or utilize  Envirofacts on
                              the Web to look up  the address or facility name
                              http://www.epa.gov/enviro.   If your facility has
                              moved,   do   not   enter  your   TRI   Facility
                              Identification  Number, enter "New  Facility". If
 32
Toxics Release Inventory Reporting Forms and Instructions

-------
                                Instructions for Completing TRI Form R
you  are  filing  a  separate  Form  R  for each
establishment at your facility, you should use the
same TRI Facility Identification Number for each
establishment.

The   TRI   Facility  Identification  Number   is
established by the  first Form R submitted by a
facility at a particular location. Only a change  in
address  warrants  filing  as  a  new  facility;
otherwise, the TRI  Facility Identification Number
is  retained  by the facility  even  if the  facility
changes name, ownership, production processes,
SIC  or NAICS  codes,  etc.  This  identification
number will stay  with this location. If a new
facility moves to this location it should use this
TRI      Facility     Identification     Number.
Establishments of a facility that report separately
should use the TRI Facility Identification Number
of the facility.

You should enter "New Facility" in  the space for
the  TRI Facility  Identification number if this  is
your first submission.

4.2     Full or Partial Facility Indication
EPCRA   Section  313   requires  reports   by
"facilities,"  which  are defined as "all buildings,
equipment, structures, and other stationary items
which are located on a single site or on contiguous
or adjacent sites  and which are owned or operated
by the  same  person  (or by any person  which
controls,  is  controlled by,  or under common
control with such person). A facility may contain
more than one establishment."

EPCRA Section  313 defines  establishment as "an
economic unit,  generally  at a  single  physical
location, where  business  is  conducted  or where
services or industrial  operations are performed."
Under Section 372.30(c) of the reporting rule, you
may  submit  a  separate  Form  R  for  each
establishment, or for  groups of establishments  in
your facility, provided all releases and other waste
management  activities  and  source   reduction
activities  involving  the  EPCRA  Section  313
chemical from the entire facility are reported. This
allows you the option of reporting separately on
the  activities involving an  EPCRA  Section 313
chemical  at each  establishment,  or  group   of
establishments (e.g.,  part of a covered facility),
rather than submitting a single  Form  R for that
EPCRA  Section  313 chemical  for  the  entire
facility. However, if an establishment or group  of
establishments does not manufacture, process, or
otherwise use or release or otherwise manage as
waste an EPCRA Section  313 chemical,  you do
not have to submit a report for that establishment
or  group of establishments  for  that  particular
chemical.  (See   also  Section  B.2.a  of  these
instructions.)

A covered facility must report all  releases and
other waste  management  activities  and source
reduction activities of an  EPCRA  Section 313
chemical if the facility meets a reporting threshold
for that EPCRA Section 313  chemical. Whether
submitting a report  for the  entire facility or
separate   reports  for  the  establishments, the
threshold  determination must  be made  based on
the entire facility.  Indicate in Section 4.2 whether
your report is for the entire covered facility as a
whole or for  part of a covered facility (i.e., one or
more establishments).

Federal  facilities  and  contractors  at  federal
facilities      (GOCOs:     Government-owned,
contractor-operated facilities) should check  either
4.2c or 4.2d,  but not both. Federal facilities should
check  4.2c,  even if their  TRI reports  contain
release and other waste management information
from   contractors  located    at   the    facility.
Contractors at federal facilities, which are required
by  EPCRA  Section   313  to  file  TRI  reports
independently of the federal facility,  should check
4.2d.  This information is  important to  prevent
duplication of federal  facility data. (See Appendix
A for further  guidance on these instructions.)

4.3     Technical Contact
Enter the name  and telephone  number (including
area code) of a technical  representative whom
EPA or state  officials may contact for clarification
of  the  information reported  on  Form  R.   You
should also enter an email address  for this person.
EPA  encourages  facilities to  provide  an  email
address for its  Technical  Contact on their TRI
submissions because they will  be  able to receive
important  program  updates   and  email  alerts
notifying them when their FDP has been  updated
and is  available  on   the  FDP website. If the
technical contact does not have an email  address
you should enter NA. This contact person does not
have to  be the  same person  who  prepares the
report or signs the certification statement and does
not necessarily need to be someone at the location
of  the  reporting  facility. However,  this person
                    Toxics Release Inventory Reporting Forms and Instructions
                                            33

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should be familiar with the details of the report so
that  he or  she can answer  questions about the
information provided.
                                         your  establishments have  been assigned D&B
                                         numbers,  enter those  numbers in Part I, section
                                         4.6.
4.4
Public Contact
Enter the name and telephone number (including
area code)  of a person  who  can  respond to
questions from the  public about the form. You
should also enter an e-mail address for this person.
If you choose to designate the same person as both
the Technical and the Public Contact, or you do
not have a  Public Contact, you may enter "Same
as Section 4.3" in this space. This contact person
does not have to be the same person who prepares
the form or signs the Certification Statement and
does not necessarily need to be someone at the
location of the reporting facility.

4.5    North American Industry Classification
       System (NAICS) Codes
The North  American  Industry  Classification
System (NAICS) is  the  economic classification
system that replaces the 1987 SIC code system for
TRI Reporting  beginning  with the  RY 2006
EPCRA  Section 313  reporting  (71 FR  32464).
Enter the appropriate six digit  North American
Industry Classification System (NAICS) Code that
is the  primary NAICS code for your facility in
Section 4.5(a). For  Reporting  Year  2008  and
beyond, use 2007 NAICS codes. Enter any other
applicable NAICS for your facility in 4.5 (b)-(f).
Table I lists the TRI-covered NAICS codes. If you
do not know your NAICS  code, consult the 2007
NAICS  Manual  (see  Section  B.2  of these
instructions for ordering information) or check the
SIC   to   NAICS   crosswalk    tables   at
http://www.census.gov

4.6    Dun & Bradstreet Number(s)
Enter the nine digit number assigned by Dun &
Bradstreet  (D&B)  for  your  facility   or  each
establishment within your facility. These  numbers
code  the  facility for  financial  purposes.  This
number may be  available from your facility's
treasurer or financial officer. You can also obtain
the numbers from Dun & Bradstreet by calling 1-
888-814-1435,  or  by visiting  this  web  site:
https://www.dnb.com/product/dlw/form cc4.htm.
If a facility does not subscribe to the D&B service,
a number can be obtained, toll  free at 800 234-
3867 (8:00 AM to 6:00 PM, Local Time) or on the
Web at http://www.dnb.com.   If none  of your
establishments has been assigned a D&B number,
you should enter NA in  box (a). If only some of
                                                 Section 5.
                                                        Parent Company
                                                        Information
                                         You must provide information  on your  parent
                                         company. For purposes of the Form R, a parent
                                         company is defined as the highest level company,
                                         located in the United States, that directly owns at
                                         least  50 percent  of the  voting  stock of your
                                         company. If your  facility is owned by a foreign
                                         entity, enter NA in this  space. Corporate  names
                                         should be treated  as parent company names  for
                                         companies  with  multiple  facility  sites.  For
                                         example, the Bestchem Corporation is not  owned
                                         or controlled by any other corporation but has sites
                                         throughout the country whose names  begin with
                                         Bestchem.  In  this case,  Bestchem  Corporation
                                         should be listed as the parent company. Note that a
                                         facility that is a 50:50 joint venture  is its own
                                         parent company.  When  a facility is  owned  by
                                         more  than one company and none of the facility
                                         owners directly  owns at least 50 percent of its
                                         voting stock, the facility should provide the name
                                         of  the parent  company  of either  the  facility
                                         operator or the owner with the largest ownership
                                         interest in the  facility. If neither  the operator nor
                                         this owner has a parent company,  then the NA box
                                         should be checked.

                                         5.1    Name of Parent Company
                                         Enter  the  name  of  the corporation or  other
                                         business  entity that is  your ultimate U.S.  parent
                                         company. If your facility has no parent company,
                                         you should check the NA box.

                                         5.2    Parent Company's Dun &  Bradstreet
                                                Number
                                         Enter the D&B  number for your ultimate U.S.
                                         parent company,  if applicable. The number may be
                                         obtained from the treasurer or financial officer of
                                         the company or by calling 1-888-814-1435, or by
                                         visiting         this          web         site:
                                         https ://www.dnb.com/product/dlw/form cc4 .htm.
                                         If your parent company does not have a D&B
                                         number, you should check the NA box.
34
            Toxics Release Inventory Reporting Forms and Instructions

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                       Instructions for Completing Part II of EPA Form R
Part II.   Chemical Specific
           Information
In Part II, you are to report on:

•   The EPCRA  Section  313 chemical  being
    reported;
•   The general uses and activities  involving the
    EPCRA Section 313 chemical at your facility;
•   On-site releases of the EPCRA Section 313
    chemical from the  facility to air, water, and
    land;
•   Quantities  of  the  EPCRA   Section  313
    chemical transferred to off-site locations;
•   Information for on-site and off-site disposal,
    treatment, energy recovery, and recycling of
    the EPCRA Section 313 chemical; and
•   Source reduction activities.

Section 1.   EPCRA Section  313
              Chemical Identity
1.1     CAS Number
Enter the  Chemical  Abstracts  Service  (CAS)
registry  number in Section  1.1  exactly  as  it
appears  in  Table II of these instructions for the
chemical being reported. CAS numbers are cross-
referenced with an alphabetical list of chemical
names in Table II. If you are reporting  one of the
EPCRA Section  313  chemical categories (e.g.,
chromium  compounds),  you  should  enter  the
applicable  category code in  the  CAS  number
space.  EPCRA Section  313 chemical category
codes are listed below  and can also be found in
Table He and Appendix B.

EPCRA Section 313 Chemical Category Codes:

NO 10   Antimony compounds
N020   Arsenic compounds
N040   Barium compounds
N050   Beryllium compounds
N078   Cadmium compounds
N084   Chlorophenols
N090   Chromium compounds
N096   Cobalt compounds
N100   Copper compounds
N106   Cyanide compounds
N120   Diisocyanates
N150   Dioxin and dioxin-like compounds
N171   Ethylenebisdithiocarbamic acid, salts and
        esters  (EBDCs)
N230   Certain glycol ethers
N420   Lead compounds
N450   Manganese compounds
N458   Mercury compounds
N495   Nickel compounds
N503   Nicotine and salts
N511   Nitrate  compounds (water dissociable,
        reportable only in aqueous solution)
N575   Polybrominated biphenyls (PBBs)
N583   Polychlorinated alkanes (CIO to C13)
N590   Polycyclic aromatic compounds (PACs)
N725   Selenium compounds
N740   Silver compounds
N746   Strychnine and salts
N760   Thallium compounds
N770   Vanadium compounds
N874   Warfarin and salts
N982   Zinc compounds

If you are making a  trade secret claim, you must
report the CAS number or category code  on your
unsanitized Form R and unsanitized substantiation
form. Do not include the CAS number or category
code on your  sanitized  Form  R  or sanitized
substantiation form.

1.2     EPCRA Section 313 Chemical or
       Chemical Category Name
Enter the name of the  EPCRA  Section  313
chemical or  chemical  category  exactly as  it
appears  in Table II.  If the EPCRA Section 313
chemical name  is followed by a  synonym  in
parentheses, report the chemical by the name that
directly  follows the  CAS number (i.e.,  not the
synonym). If the EPCRA Section  313 chemical
identity  is actually a product  trade name (e.g.,
Dicofol), the 9th Collective Index name  is listed
below it in brackets.  You may report either name
in this case.

Do not list the name of a chemical that does not
appear in Table II, such as individual members  of
an EPCRA Section  313  chemical  category. For
example, if you use silver chloride, do  not report
silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category
code, N740.

If you are making a  trade secret claim, you must
report the specific EPCRA Section 313 chemical
identity  on   your   unsanitized  Form  R  and
unsanitized substantiation form. Do not report the
name of the EPCRA Section 313 chemical on your
                  Toxics Release Inventory Reporting Forms and Instructions
                                         35

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sanitized Form R or sanitized substantiation form.
Include   a generic  name  that  is  structurally
descriptive in Part II, Section 1.3 of your sanitized
Form R report.

EPA  requests  that  the EPCRA Section  313
chemical, chemical category, or generic name also
be placed in the box marked  "Toxic Chemical,
Category, or  Generic Name" in the upper right-
hand corner on all pages of Form R. While this
space is not a required data element, providing this
information will help you in preparing a complete
Form R report.
1.3
Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section 2.1 on Page 1 of Form R. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic name to
seventy characters  (e.g., numbers, letters, spaces,
punctuation) or less.  Do not enter mixture names
in Section  1.3; see Section 2 below.

In-house plant codes and  other substitute names
that are not structurally descriptive of the EPCRA
Section 313 chemical identity  being withheld as a
trade secret are not acceptable as a generic  name.
The generic name  must appear on both sanitized
and unsanitized Form Rs,  and the name must be
the same as that used on your substantiation forms.
Section 2.   Mixture Component
              Identity

Do  not  complete  this  section  if  you  have
completed Section 1 of Part II. Report the generic
name provided to you by  your supplier in this
section if your supplier is claiming the chemical
identity proprietary or trade secret. Do not answer
"yes" in Part I, Section 2.1 on Page 1 of the form
if you complete this section. You do not need to
supply trade secret  substantiation forms for this
EPCRA Section 313 chemical because  it is your
supplier who is claiming the  chemical  identity a
trade secret.
Example    10:    Mixture   Containing
Unidentified   EPCRA   Section    313
Chemical

Your facility  uses  20,000 pounds  of  a
solvent  that  your supplier has told  you
contains 80 percent "chlorinated  aromatic,"
their generic name for a non-PBT EPCRA
Section  313 chemical  subject  to reporting
under EPCRA Section  313. You, therefore,
have used 16,000 pounds of some EPCRA
Section  313 chemical and that exceeds the
"otherwise  use"  threshold  for a non-PBT
chemical. You would file a Form R and enter
the name "chlorinated aromatic" in the space
provided in Part II, Section 2.
                                         2.1    Generic Chemical Name  Provided  by
                                                Supplier

                                         Enter the  generic chemical name in this section
                                         only if the following three conditions apply:

                                                1.)  You  determine  that  the  mixture
                                         contains an EPCRA Section 313 chemical but the
                                         only identity you have  for that chemical is a
                                         generic name;

                                                2.)  You  know  either  the  specific
                                         concentration  of  that  EPCRA  Section 313
                                         chemical component or a maximum or average
                                         concentration level; and

                                                3.) You multiply the  concentration level
                                         by the total annual amount of the whole mixture
                                         processed  or otherwise used  and determine that
                                         you  meet  the process or  otherwise use threshold
                                         for  that  single,  generically  identified mixture
                                         component.

                                         Section 3.   Activities and Uses of the
                                                       EPCRA Section 313
                                                       Chemical at the Facility

                                         Indicate  whether  the   EPCRA  Section 313
                                         chemical is manufactured (including  imported),
                                         processed, or otherwise used at the facility and the
                                         general nature  of such activities  and uses at the
                                         facility during the calendar year (see  Figure  3).
                                         You are not required to report on Form R the
                                         quantity manufactured,  processed  or  otherwise
                                         used. Report activities that take place only at your
                                         facility,  not activities  that take place  at  other
                                         facilities involving your products.  You must check
                                         all the boxes in this section that apply. Refer to the
36
            Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
definitions   of "manufacture,"  "process,"  and    and/or (b), and at least one of (c), (d), (e), and (f)
"otherwise use" in the general information section    in Section 3.1.
of these instructions or Part 40, Section 372.3 of
the Code  of Federal  Regulations  for  additional
3.2
explanations.

3.1    Manufacture the EPCRA Section 313
       Chemical
Persons who manufacture (including import) the
EPCRA Section 313  chemical must check at least
one of the following:

a.    Produce  —   The   EPCRA   Section  313
     chemical is produced at the facility.
b.    Import  —  The  EPCRA  Section  313
     chemical is imported by the facility into the
     Customs Territory of the United States. (See
     Section  B.3.a   of  these  instructions for
     further clarification of import.)

And check at least one of the following:

c.    For on-site use/processing — The EPCRA
     Section  313   chemical   is  produced  or
     imported  and  then  further  processed  or
     otherwise used at the same  facility.  If you
     check this block, generally you should also
     check at least one item in Part II, Section 3.2
     or 3.3.
d.    For  sale/distribution  —   The  EPCRA
     Section  313   chemical   is  produced  or
     imported specifically for sale or distribution
     outside the manufacturing facility.
e.    As a byproduct — The EPCRA Section 313
     chemical is  produced coincidentally  during
     the manufacture, processing,  or  otherwise
     use  of  another  chemical   substance  or
     mixture  and,  following  its  production,  is
     separated   from   that   other   chemical
     substance or mixture. EPCRA Section 313
     chemicals produced as a result of waste
     management are also considered byproducts.
f.    As an impurity — The EPCRA Section 313
     chemical  is produced coincidentally as  a
     result  of the  manufacture,  processing, or
     otherwise use of another chemical but is not
     separated and  remains  in the mixture or
     other trade  name product with that other
     chemical.

In summary, if you  are a manufacturer  of the
EPCRA Section 313 chemical, you must check (a)
       Process   the  EPCRA  Section   313
       Chemical
Persons who process the EPCRA  Section  313
chemical must check at least one of the following:
a.
b.
c.
d.
e.
    As a  reactant  — A natural  or synthetic
    EPCRA  Section 313  chemical is  used in
    chemical  reactions for the  manufacture of
    another chemical substance or of a product.
    Includes but is not limited to, feedstocks, raw
    materials, intermediates, and initiators.
    As a formulation component — An EPCRA
    Section 313 chemical is added to a  product
    (or  product  mixture)  prior  to   further
    distribution of the product that acts  as a
    performance  enhancer  during  use  of  the
    product.  Examples of EPCRA Section 313
    chemicals used in this capacity include,  but
    are not limited to, additives, dyes,  reaction
    diluents,   initiators,   solvents,   inhibitors,
    emulsifiers,  surfactants,  lubricants,  flame
    retardants, and rheological modifiers.
    As an  article  component —  An  EPCRA
    Section 313  chemical becomes an  integral
    component  of  an  article  distributed  for
    industrial,  trade,  or  consumer  use.  One
    example is the pigment components of paint
    applied to a chair that is sold.
    Repackaging — This consists of processing
    or preparation  of an  EPCRA  Section 313
    chemical (or product mixture) for distribution
    in commerce in a different form, state, or
    quantity. This includes, but is not limited to,
    the transfer of material from a bulk container,
    such as  a tank  truck  to smaller containers
    such as cans or bottles.
    As an  impurity — The EPCRA Section 313
    chemical  is processed but is  not separated
    and  remains in  the  mixture  or other  trade
    name   product   with   that/those    other
    chemical(s).
3.3
       Otherwise Use the EPCRA Section 313
       Chemical (non-incorporative activities)
Persons who otherwise use the EPCRA  Section
313  chemical must  check at least one  of the
following:
                   Toxics Release Inventory Reporting Forms and Instructions
                                           37

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      As a chemical processing aid — An EPCRA
      Section 313  chemical  that  is added  to  a
      reaction mixture to aid in the manufacture or
      synthesis of another chemical  substance but
      is not intended to remain in or become part of
      the product or product  mixture is  otherwise
      used as chemical processing aid. Examples of
      such EPCRA  Section 313 chemicals include,
      but are  not  limited to,  process   solvents,
      catalysts,   inhibitors,   initiators,   reaction
      terminators, and solution buffers.
      As a  manufacturing aid —  An EPCRA
      Section  313   chemical  that   aids   the
      manufacturing process but does not become
      part of the  resulting product and is  not added
      to   the    reaction   mixture    during   the
                                                            manufacture or synthesis of another chemical
                                                            substance   is   otherwise    used    as   a
                                                            manufacturing aid. Examples include, but are
                                                            not    limited    to,    process    lubricants,
                                                            metalworking fluids,  coolants,  refrigerants,
                                                            and hydraulic fluids.
                                                            Ancillary  or other  use  —  An  EPCRA
                                                            Section 313 chemical that is used at a facility
                                                            for  purposes other  than  aiding  chemical
                                                            processing or manufacturing  as  described
                                                            above is otherwise  used as  an ancillary or
                                                            other  use. Examples  include,  but are  not
                                                            limited to,  cleaners,  degreasers,  lubricants,
                                                            fuels,  EPCRA Section 313  chemicals  used
                                                            for treating wastes, and EPCRA Section 313
                                                            chemicals used to treat water at the facility.
    SECTION 1.  TOXIC CHEMICAL IDENTITY
                                               (Important: DO NOT complete this section if you completed Section 2 below.)
    1.1
         CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
          334-88-3
    1.2
         Toxic Chemical or Chemical Category Name (Important: Enter only ore name exactly as it appears on the Section 313 list.)
          Diazomethane
    1.3
         Generic Chemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
    1.4  Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category.
         (If there are any numbers in boxes 1-17, then every field must be filled in with either 0 or some number between 0.01 and 100. Distribution should
         be reported in percentages and the total should equal 0 or 100%. If you do not have speciatson data available, check NA.)
            1     2     3     4     5     6      7     8     9     10    11    12     13    14    15    16    17
    NA
    SECTION 2.  MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
    2.1
         Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
    SECTION 3.  ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
               (Important: Check all that apply.)
    3.1   Manufacture the toxic chemical:
                                        3.2  Process the toxic chemical:
                                                                       3.3  Otherwise use the toxic chemical:
       a.  X   Produce   b.
                             Import
              If produce or import:
              Foron-site use/processing

              For sale/distribution

              As a byproduct

              As an impurity
                                            X
                                                As a reactant

                                                As a formulation component

                                                As an article component

                                                Repackaging

                                                As an impurity
                       As a chemical processing aid
                       As a manufacturing aid

                       Ancillary or other use
                         Figure 3. Reporting EPCRA Section 313 Chemicals
Section 4.
                Maximum Amount of the
                EPCRA Section 313
                Chemical On-site at Any
                Time during the Calendar
                Year
For data element 4.1 of Part II, insert the code (see
codes  below) that indicates the maximum quantity
of the  EPCRA Section 313 chemical (e.g., in storage
tanks,  process vessels,  on-site shipping  containers,
or in wastes generated) at your facility at any time
during the calendar year. If the EPCRA Section 313
chemical was present  at  several  locations within
your facility, use the maximum total amount present
at the  entire facility at any  one time. While range
reporting  is   not  allowed  for  PBT   chemicals
elsewhere on the Form R, range reporting for PBT
chemicals is allowed for the Maximum Amount On-
site.
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                       Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
Example  11:  Manufacturing  and  Processing
Activities of EPCRA Section 313 Chemicals
In the two examples below, it is assumed that the
threshold quantities  for manufacture,  process, or
otherwise use (25,000 pounds, 25,000 pounds, and
10,000   pounds,   respectively  for   non-PBT
chemicals; 100 pounds for certain PBT chemicals;
10   pounds   for  highly   persistent,   highly
bioaccumulative toxic chemicals; and 0.1 grams
for the PBT chemical category comprised of dioxin
and dioxin-like  compounds) have been  exceeded
and  the  reporting   of  EPCRA  Section   313
chemicals is therefore required.
1. Your facility manufactures diazomethane. Fifty
percent is sold as a  product, thus it is processed.
The remaining fifty percent is reacted with alpha-
naphthylamine,     forming     N-methyl-alpha-
naphthylamine and also producing nitrogen gas.
D  Your company manufactures diazomethane,
     an EPCRA Section  313 chemical, both for
     sale/ distribution as  a  commercial product
     and for on-site  use/processing as a feedstock
     in   the    N-methyl-alpha-naphthylamine
     production     process.    Because     the
     diazomethane  is  a  reactant,   it   is  also
     processed.  See  Figure  3  for how   this
     information  would be  reported in Part II,
     Section 3 of Form R.

D  Your   facility   also   processes   alpha-
     naphthylamine,  as a reactant to produce N-
     methyl-alpha-naphthylamine, a chemical not
     on the EPCRA  Section 313 list.

2. Your  facility is  a commercial distributor of
Missouri bituminous coal, which contains mercury
at 1.5 ppm (w:w). You should check the box on the
Form  R at Part II,  Section  3.2.e for processing
mercury as an impurity.
Weight Range in Pounds
Range Code
01
02
03
04
05
06
07
08
09
10
11
     From...
          0
        100
      1,000
     10,000
    100,000
  1,000,000
 10,000,000
 50,000,000
100,000,000
500,000,000
 1 billion
          To...
            99
           999
         9,999
        99,999
       999,999
      9,999,999
    49,999,999
    99,999,999
   499,999,999
   999,999,999
more than 1 billion
If the EPCRA Section 313 chemical present at your
facility was part of a mixture or other trade name
product, determine the  maximum  quantity of the
EPCRA Section 313 chemical present at the facility
by calculating  the  weight percent of the  EPCRA
Section 313 chemical only.

Do not include the weight of the entire mixture or
other trade name product. These data may be found
in the Tier II form your facility may have prepared
under Section 312 of EPCRA. See  Part 40, Section
372.30(b) of the Code of Federal  Regulations for
further information on how to calculate the weight
of the EPCRA  Section 313 chemical in the mixture
or other trade name product. For EPCRA Section
313  chemical categories  (e.g., nickel  compounds),
include  all  chemical compounds in the category
when calculating the maximum  amount, using the
entire weight of each compound.  When reporting
for dioxin and dioxin-like compounds you should
convert the maximum amount from grams to pounds
before  choosing the appropriate  range code  in
Section 4 of Part II.
                                                Section 5.    Quantity of the EPCRA
                                                              Section 313 Chemical
                                                              Entering Each
                                                              Environmental Medium On-
                                                              site
                                                In  Section  5, you must account  for the  total
                                                aggregate  on-site  releases  of the EPCRA Section
                                                313 chemical to the environment from your facility
                                                for the calendar year.
                    Toxics Release Inventory Reporting Forms and Instructions
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On-site  releases  to  the  environment  include
emissions to the  air, discharges to surface waters,
and  releases to  land  and  underground  injection
wells.

For  all toxic chemicals  (except  the dioxin and
dioxin-like compound  category), do not enter the
values in  Section 5 in gallons, tons,  liters, or any
measure other than pounds. You must also enter the
values as whole numbers  (do  not use scientific
notation).  Numbers following a decimal point are
not acceptable for toxic chemicals other than those
designated as PBT chemicals. For PBT chemicals,
facilities   should  report  release and other  waste
management quantities  greater  than 0.1  pound
(except the  dioxin  and  dioxin-like  compounds
category), provided the accuracy and the underlying
data on which the estimate is  based supports this
level of precision.

For the dioxin and dioxin-like compounds category,
facilities   should  report  at a  level  of precision
supported by the accuracy  of the underlying data
and the estimation techniques on which the estimate
is based.  For the dioxin and dioxin like compounds
chemical category, which has a reporting threshold
of 0.1  gram, facilities  need only report all release
and other  waste management quantities greater than
100 micrograms (i.e., 0.0001 grams). (See Example
12.)  Notwithstanding the numeric precision  used
when determining reporting eligibility  thresholds,
facilities  should report on  Form R to the level of
accuracy that their data supports, up to seven digits
to the right of the decimal. EPA's reporting software
and   data  management   systems  support   data
precision  up to seven digits to the right of the
decimal.
 Example 12: Reporting Dioxins and Dioxin-
 Like Compounds

 If the total quantity for Section 5.2 of the Form
 R (i.e., stack or point air emissions) is 0.00005
 grams or less, then zero can be  entered. If the
 total quantity is between 0.00005 and 0.0001
 grams, then 0.0001 grams can be entered or the
 actual number can be entered (e.g., 0.000075).
                             contained the EPCRA Section 313 chemical is not
                             directed to the relevant environmental medium, or if
                             leaks, spills and fugitive emissions cannot occur. If
                             the  waste stream  that contains or contained  the
                             EPCRA  Section 313 chemical is directed  to  the
                             environmental medium, or if leaks, spills or fugitive
                             emissions can occur, NA should not be used, even if
                             treatment or emission controls result in a release of
                             zero.  If the  annual  aggregate  release of  that
                             chemical was equal to or less than 0.5 pound, the
                             value reported is zero (unless the chemical is a listed
                             PBT chemical).

                             For Section 5.1, NA generally is not applicable for
                             volatile  organic compounds  (VOCs).  For Section
                             5.5.4, NA  generally  would not  be  applicable,
                             recognizing  the possibility of accidental spills  or
                             leaks of the EPCRA Section 313 chemical.

                             An  example that illustrates the use of  NA vs. a
                             numeric  value  (e.g.,  zero)  would be  nitric  acid
                             involved in a facility's processing activities. If the
                             facility neutralizes  the wastes containing  nitric acid
                             to a pH of 6 or above, then the  facility reports a
                             release  of  zero   for  the EPCRA   Section  313
                             chemical, not NA. Another  example is  when  the
                             facility has no underground injection well, in which
                             case NA should be entered in Part I, Section  4.10
                             and checked in Part II, Section 5.4.1 and 5.4.2 of
                             Form R. Also,  if the facility  does not landfill the
                             acidic waste, NA  should be checked in Part  II,
                             Section 5.5.1.B  of Form R.

                             All  releases of the  EPCRA Section 313 chemical to
                             the  air must be  classified as either stack or fugitive
                             emissions,  and included  in  the  total quantity
                             reported  for these releases in Sections  5.1 and 5.2.
                             Instructions  for columns A,  B, and C follow  the
                             discussions of Sections 5.1 through 5.5.
                                                   5.1
                                      Fugitive or Non-Point Air Emissions
NA vs. a Numeric Value (e.g., Zero). Generally,
NA is applicable if the waste stream that contains or
                             Report the  total of all releases  of the EPCRA
                             Section 313  chemical to the air that are not released
                             through stacks,  vents,  ducts, pipes, or  any other
                             confined  air stream. You must include (1) fugitive
                             equipment leaks from valves, pump seals, flanges,
                             compressors,  sampling  connections,  open-ended
                             lines,  etc.;  (2)  evaporative  losses  from  surface
                             impoundments and spills; (3) releases from building
                             ventilation systems; and (4) any other fugitive  or
                             non-point air emissions. Engineering estimates and
                             mass balance calculations (using purchase records,
                             inventories,   engineering  knowledge  or process
                             specifications of the quantity of the EPCRA Section
                             313  chemical entering  product,  hazardous waste
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                          Instructions for Completing Part II of EPA Form R
manifests, or monitoring records) may be useful in
estimating fugitive emissions. You should check the
NA box in Section  5.1  if you  do not engage in
activities that result in  fugitive  or non-point air
emissions of this listed toxic chemical. For VOCs,
NA generally would not be applicable.
5.2    Stack or Point Air Emissions

Report the  total  of all releases  of the EPCRA
Section 313 chemical to the air that occur through
stacks,  confined  vents,  ducts,  pipes,  or  other
confined  air streams. You must include storage tank
emissions.  Air  releases from air pollution control
equipment  would generally fall  in  this category.
Monitoring  data,  engineering estimates,  and mass
balance calculations may help you to complete this
section. You should check the NA box in  Section
5.2 if there are  no stack air activities involving the
waste stream that  contains or contained the EPCRA
Section 313 chemical.

5.3    Discharges to Receiving Streams or
       Water Bodies

In Section 5.3 you are to enter all the names of the
streams  or  water bodies to which  your  facility
directly  discharges  the  EPCRA  Section  313
chemical on which you are reporting.  A total of
three spaces is provided on Page 2 of Form R. Enter
the name of each  receiving stream or surface water
body  to  which  the  EPCRA Section 313 chemical
being reported  is directly  discharged. Report the
name of the receiving  stream  or water  body as it
appears on the permit for the facility. If the stream is
not included in the NPDES permit or its name is not
identified in the NPDES permit, enter the name of
the off-site  stream  or  water body  by which it  is
publicly  known or  enter the first publicly  named
water body to  which  the receiving waters  are a
tributary, if the receiving waters are unnamed. Do
not list  a  series of  streams  through  which the
EPCRA  Section 313  chemical flows. Be  sure to
include all the receiving streams or water bodies that
receive stormwater runoff from your facility. Do not
enter names of streams to which off-site treatment
plants discharge. You should enter NA  in  Section
5.3.1 if there are no discharges to receiving streams
or water  bodies of the waste stream that contains or
contained the EPCRA  Section  313 chemical (See
discussion of NA vs. a Numeric Value (e.g., Zero)
in the introduction of Section 5).
Enter the total annual amount of the EPCRA Section
313 chemical released from all discharge points at
the facility to each receiving stream or water body.
Include process outfalls such as pipes and  open
trenches, releases from on-site wastewater treatment
systems, and the  contribution  from stormwater
runoff, if applicable (see instructions for column C
below). Do not include discharges to a POTW or
other off-site wastewater treatment facilities in this
section. These off-site transfers must be reported in
Part  II, Section 6 of Form  R. Wastewater analyses
and flowmeter data may provide the  quantities you
will need to complete this section.

Discharges of listed acids (e.g., hydrogen fluoride,
nitric acid) may be reported as zero if the discharges
have  been  neutralized  to pH  6   or  above.  If
wastewater containing  a listed acid is discharged
below  pH  6,  then releases of the  acid  must be
reported. In this case,  pH measurements may be
used  to estimate the  amount  of  mineral   acid
released.

5.4.1    Underground Injection On-Site to Class I
        Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected  into Class I wells at the
facility. Chemical analyses, injection rate meters,
and RCRA Hazardous Waste Generator Reports are
good sources for obtaining data that will be useful in
completing this section. You should  check the NA
box in Section  5.4.1 if you do not inject the waste
stream  that  contains  or  contained  the  EPCRA
Section 313  chemical  into Class  I underground
wells (See  discussion of NA vs. a Numeric Value
(e.g., Zero) in the introduction of Section 5).
5.4.2    Underground Injection On-site to Class II-
        V Wells
Enter the total amount of the EPCRA Section 313
chemical that was injected into wells at the facility
other  than Class I  wells. Chemical analyses and
injection rate meters are good sources for obtaining
data that will be useful in completing this section.
You should check the  NA box in Section 5.4.2 if
you do not inject the waste stream that contains or
contained the EPCRA Section 313  chemical into
Class II-V underground wells (See discussion of NA
vs. a Numeric Value (e.g., Zero) in the introduction
of Section 5).
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                                             41

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5.5    Disposal to Land On-site
Five   predefined   subcategories   for   reporting
quantities released to land within the boundaries of
the facility are provided. Do not report land disposal
at off-site   locations  in  this  section.  Accident
histories  and spill records  may be useful (e.g.,
release notification reports required under Section
304  of EPCRA,   Section 103  of CERCLA,  and
accident       histories      required       under
Sectionll2(r)(7)(B)(ii)   of the  Clean   Air  Act).
Where relevant, you should check the  NA box in
sections  5.5.1 A  through  5.5.3  if there are  no
disposal activities for the waste stream that contains
or contained the EPCRA Section 313 chemical (See
discussion of NA vs. a Numeric Value  (e.g., Zero)
in the introduction of Section 5). For 5.5.4, facilities
generally  should  report  zero,  recognizing  the
potential for spills or leaks.

5.5.1A RCRA Subtitle C landfills
Enter the total amount of the EPCRA Section  313
chemical that was placed in  RCRA  Subtitle C
landfills. EPA has not required facilities to estimate
leaks from  landfills because  the  amount of the
EPCRA  Section  313 chemical  has already been
reported as a release.

5.5. IB Other landfills
Enter the total amount of the EPCRA Section  313
chemical that was placed in  landfills  other than
RCRA Subtitle C landfills. EPA has not required
facilities to estimate leaks from landfills  because the
amount of the  EPCRA Section  313 chemical  has
already been reported as a release.

5.5.2  Land treatment/application farming
Land treatment is a disposal  method  in which a
waste containing an EPCRA Section 313 chemical
is applied onto or incorporated into soil. While  this
disposal method is considered a release to land, any
volatilization of EPCRA Section 313 chemicals  into
the air occurring during the disposal operation must
not be included in this section but must  be included
in the total fugitive air releases reported in Part II,
Section 5.1 of Form R.

Surface Impoundments
A surface impoundment is  a natural topographic
depression,  man-made  excavation,  or  diked area
formed primarily  of earthen  materials  (although
some may be lined with man-made  materials),  that
is designed to hold an accumulation of liquid wastes
or wastes  containing  free  liquids. Examples of
                            surface impoundments are holding, settling, storage,
                            and elevation pits;  ponds, and lagoons. If the pit,
                            pond, or lagoon is  intended for storage or holding
                            without discharge, it would be considered to be a
                            surface impoundment used  as  a final  disposal
                            method. A facility must determine, to the best of its
                            ability, the percentage  of a volatile chemical, e.g.,
                            benzene,  that is  in  waste  sent to  a  surface
                            impoundment that evaporates  during the reporting
                            year. The facility must report  this as a fugitive air
                            emission  in  section 5.1. The balance  should be
                            reported in either section 5.5.3A or 5.5.3B.

                            Quantities of the EPCRA  Section 313 chemical
                            released  to surface impoundments that are used
                            merely as part of a wastewater treatment process
                            generally  should not be  reported in  this section.
                            However, if an impoundment  accumulates sludges
                            containing the EPCRA Section 313 chemical, you
                            must include an estimate in this section unless the
                            sludges are removed and otherwise  disposed  (in
                            which case  they  must  be  reported  under the
                            appropriate section of the form). For the purposes of
                            this reporting, storage tanks are not considered to be
                            a type of  disposal and are not to be reported in this
                            section of Form R.

                            5.5.3A RCRA Subtitle C Surface Impoundments
                            Enter the  total amount of the  EPCRA Section 313
                            chemical  that was placed  in RCRA  Subtitle  C
                            surface impoundments.

                            5.5.3B Other Surface Impoundments
                            Enter the  total amount of the  EPCRA Section 313
                            chemical that was placed in surface impoundments
                            other than RCRA Subtitle C surface impoundments.

                            5.5.4  Oth er Disposal
                            Includes  any  amount of an EPCRA  Section 313
                            chemical  released  to land  that  does  not fit the
                            categories of landfills, land treatment,  or  surface
                            impoundment. This other disposal would  include
                            any spills  or leaks of EPCRA Section 313 chemicals
                            to land. For example, 2,000 pounds of benzene leaks
                            from an  underground pipeline into the land at a
                            facility. Because the pipe was  only a few feet from
                            the surface at the  erupt point, 30 percent  of the
                            benzene evaporates into  the air.  The 600  pounds
                            released to the air would be reported as a fugitive air
                            release (Part  II,  Section 5.1) and the remaining
                            1,400 pounds would be reported as a release to land,
                            other disposal (Part II, Section 5.5.4).
   42
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                          Instructions for Completing Part II of EPA Form R
Section 5 Column A: Total Release

Only on-site releases of the EPCRA Section 313
chemical to the  environment for the calendar year
are to be reported in this section of Form R. The
total  on-site releases  from  your  facility  do not
include  transfers  or  shipments  of  the  EPCRA
Section 313 chemical from your facility for sale or
distribution in  commerce, or of wastes  to  other
facilities for disposal, treatment, energy recovery, or
recycling  (see  Part  II,   Section   6   of  these
Instructions). Both routine releases, such as fugitive
air  emissions,  and  accidental  or  non-routine
releases, such as chemical  spills, must be included
in your estimate of the quantity released.

Releases of Less  Than 1,000 Pounds. For total
annual releases or off-site  transfers of an EPCRA
Section 313 chemical from the facility of less than
1,000 pounds, the amount may be reported either as
an estimate or by  using the range  codes that have
been  developed  (range reporting in section 5 does
not apply to PBT  chemicals). The reporting  range
codes to be used are:
        Code
        A
        B
        C
Range (pounds)
1-10
11-499
500-999
Do not enter a range code and an estimate in the
same box in column A. Total annual on-site releases
of an EPCRA Section 313 chemical from the facility
of less than 1  pound  may be  reported in one of
several ways.  You should round the value  to the
nearest pound.  If the estimate  is greater  than 0.5
pound, you  should either enter the range code "A"
for "1-10" or enter "1" in column A. If the release is
equal to or less than 0.5 pound, you may  round to
zero and enter "0" in column A.

Note that total annual releases of 0.5 pound or less
from the processing or otherwise use of an article
maintain the article status  of that item. Thus,  if the
only releases  you have  are from processing an
article, and  such  releases  are equal to  or less than
0.5 pound per year, you are not required to  submit a
report  for that EPCRA Section 313 chemical. The
0.5-pound release determination does not  apply to
just  a  single article. It applies to the  cumulative
releases from the  processing or otherwise use of the
same type of article (e.g., sheet metal or plastic film)
that occurs over the course of the reporting year.
Releases of 1,000 Pounds or More. For releases to
any medium that amount to 1,000 pounds or more
for the year, you must provide an estimate in pounds
per year in column  A. Any estimate provided in
column  A need not be reported to more than two
significant figures. This estimate should be in whole
numbers. Do not use decimal points.

Calculating  On-Site  Releases.  To  provide the
release information  in  column A,  EPCRA  Section
313(g)(2) requires a facility to use  readily available
data (including monitoring data) collected pursuant
to other provisions of law, or, where such data are
not readily available, "reasonable  estimates" of the
amounts involved.   If  available   data  (including
monitoring   data)   are   known   to   be   non-
representative,  facilities must make   reasonable
estimates   using  the   best  readily   available
information.

Reasonable  estimates  of  the  amounts  released
should be made using published  emission  factors,
material   balance   calculations,   or  engineering
calculations. You may not use emission factors or
calculations to estimate releases  if more  accurate
data are available.

No additional monitoring or measurement  of the
quantities or concentrations of any EPCRA  Section
313 chemical  released into the  environment, or of
the frequency of such releases, beyond that required
under other provisions of law or  regulation or as
part of routine plant operations, is required for the
purpose of completing Form R.

You must estimate the quantity (in pounds) of the
EPCRA Section 313  chemical or chemical category
that  is  released annually to each environmental
medium on-site. Include only the quantity  of the
EPCRA Section 313 chemical in this estimate. If the
EPCRA  Section 313  chemical  present  at your
facility was part of a mixture or  other trade name
product, calculate only the  releases of the EPCRA
Section  313 chemical, not the other components of
the mixture or other trade name product. If you are
only able to estimate the releases  of the  mixture or
other trade name product as a  whole, you  should
assume that the release of the EPCRA Section 313
chemical is proportional to its concentration in the
mixture or other trade name  product. See  Part 40,
Section372.30(b)   of   the   Code  of   Federal
Regulations for further information  on  how to
calculate  the  concentration  and  weight  of the
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EPCRA  Section 313  chemical in the  mixture  or
other trade name product.

If you   are  reporting  an  EPCRA  Section 313
chemical category  listed in  Table II  of these
instructions rather than a specific EPCRA Section
313 chemical, you must combine the release data for
all chemicals in the EPCRA Section 313 chemical
category (e.g., all listed members of certain glycol
ethers or all listed members  of chlorophenols) and
report  the  aggregate  amount for that  EPCRA
Section  313 chemical in that  category separately.
For example, if your facility releases 3,000 pounds
per year of 2-chlorophenol, 4,000 pounds per year
of 3-chlorophenol, and 4,000 pounds per year of 4-
chlorophenol to air as fugitive  emissions, you must
report that your facility releases 11,000 pounds per
year of chlorophenols to air as fugitive emissions in
Part II, Section 5.1.
For aqueous ammonia solutions, releases must be
reported based on  10  percent  of total  aqueous
ammonia. Ammonia  evaporating from  aqueous
ammonia solutions is considered  to be anhydrous
ammonia; therefore, 100 percent of the anhydrous
ammonia should be  reported if it is released to the
environment.  For dissociable  nitrate  compounds,
release estimates should be based on the weight of
the nitrate only.

For  metal  category  compounds  (e.g.,  chromium
compounds),  report  releases  of  only  the parent
metal.  For  example,  a  user of  various inorganic
chromium salts would report  the  total  chromium
released  regardless of the chemical compound and
exclude any contribution to mass made by the other
portion of the compound.

Section 5 Column B: Basis of Estimate

For  each release and otherwise  managed  waste
estimate  (Sections 5  & 6), you  are required  to
indicate the principal method used to determine the
amount  of  release and  otherwise  managed  waste
reported. You should enter a letter code identifying
the method that applies to the largest portion of the
total estimated release  and otherwise managed waste
quantity.

The codes are as follows:

Ml  Estimate  is  based on continuous  monitoring
     data or measurements for the EPCRA Section
     313 chemical
M2  Estimate  is based on  periodic  or  random
     monitoring  data or measurements  for  the
     EPCRA Section 313 chemical
                            C    Estimate   is   based   on   mass   balance
                                  calculations, such as calculation of the amount
                                  of the EPCRA  Section  313  chemical  in
                                  streams   entering   and   leaving   process
                                  equipment.
                            El    Estimate  is  based  on  published  emission
                                  factors, such as those relating release quantity
                                  to  through-put or equipment type  (e.g.,  air
                                  emission factors).
                            E2    Estimate  is based  on-site specific  emission
                                  factors, such as those relating release quantity
                                  to  through-put or equipment type  (e.g.,  air
                                  emission factors).
                            O    Estimate is based on other approaches such as
                                  engineering  calculations  (e.g., estimating
                                  volatilization  using  published mathematical
                                  formulas) or best engineering judgment. This
                                  would include applying an estimated removal
                                  efficiency to  a waste  stream,  even if the
                                  composition of the stream before  treatment
                                  was fully  identified through monitoring data.

                            For example, if 40 percent of stack emissions of the
                            reported EPCRA Section 313 chemical were derived
                            using  source testing data,  30  percent  by mass
                            balance,  and 30  percent by published chemical-
                            specific emission factors, you should enter the code
                            letter  "M2" for periodic  or  random  emission
                            monitoring.

                            If the  monitoring data, mass balance, or emission
                            factor used to estimate the release is not specific to
                            the  EPCRA Section 313 chemical being  reported,
                            the  form should identify the  estimate as  based on
                            other methods of estimation (O).

                            If a mass balance calculation yields the flow rate of
                            a waste,  but the  quantity   of reported  EPCRA
                            Section 313  chemical  in the waste  is based  on
                            solubility data,  you should  report "O"  because
                            engineering  calculations were used as the basis of
                            estimate of the  quantity of the EPCRA Section 313
                            chemical in the waste.

                            If the concentration of the  EPCRA  Section  313
                            chemical in  the waste was measured by continuous
                            emissions monitoring equipment and the  flow  rate
                            of the  waste was determined by mass balance, then
                            the   primary basis   of the  estimate  should  be
                            "continuous  emission   monitoring"  (Ml).  Even
                            though a mass balance calculation also contributed
                            to the estimate, "continuous emission monitoring"
                            should be indicated because monitoring data were
                            used to estimate the concentration of the chemical in
                            waste.
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                          Instructions for Completing Part II of EPA Form R
Mass balance (C) should only be indicated if it is
directly used to  calculate the mass (weight)  of
EPCRA Section 313 chemical released. Monitoring
data should be indicated as the basis  of estimate
only  if  the   EPCRA   Section  313   chemical
concentration is measured in the waste. Monitoring
data should not be indicated,  for example, if the
monitoring data relate to  a concentration of the
EPCRA  Section  313  chemical in  other process
streams within the facility.

It  is  important to  realize  that the  accuracy and
proficiency of release estimation will improve over
time.  However, submitters  are not required to use
new emission factors or estimation  techniques to
revise previous  Form R submissions.

Section 5 Column C: Percent from Stormwater

This column relates only to Section 5.3 - discharges
to  receiving streams or water bodies. If your facility
has monitoring  data on the amount of the EPCRA
Section  313   chemical   in  stormwater  runoff
(including unchanneled runoff), you must  include
that quantity of the EPCRA Section 313 chemical in
your water release  in column A  and indicate the
percentage  of the total quantity (by weight) of the
EPCRA  Section  313  chemical   contributed  by
stormwater in column C (Section 5.3C).

If  your facility  has monitoring  data on the EPCRA
Section 313 chemical and an estimate of flow rate,
you must use these data to determine  the  percent
stormwater.
If you have monitored stormwater but did not detect
the EPCRA Section 313  chemical,  enter zero in
column C.  If your  facility  has  no  stormwater
monitoring data for the chemical, you should enter
NA in this space on the form.

If your facility does not have periodic measurements
of stormwater releases of the EPCRA Section 313
chemical,   but has   submitted  chemical-specific
monitoring data in permit applications,  then  these
data must  be  used  to  calculate  the  percent
contribution from  stormwater. One way to calculate
the flow  rates  from  stormwater  runoff is the
Rational Method.  In this method, flow rates, Q, can
be estimated by multiplying  the land area of the
facility, A, by the runoff coefficient, C, and then
multiplying  that   figure  by  the  annual rainfall
intensity, I (i.e., Q = A*C*I).  The rainfall intensity,
I, is specific to the geographical area of the country
where the facility  is located,  and may be obtained
from  most  standard  engineering  manuals  for
hydrology. The flow rate, Q, will have  volumetric
dimensions  per unit  time, and will have  to  be
converted  to units of  pounds per year. The runoff
coefficient represents  the fraction  of rainfall that
does not  seep into the  ground but runs off as
stormwater. The runoff coefficient is directly related
to how the land in the drainage  area is  used. (See
table below)
Description of Land Area    Runoff Coefficient    Description of Land Area   Runoff Coefficient
Business
   Downtown areas           0.70-0.95
   Neighborhood areas        0.50-0.70
Industrial
   Light areas                0.50-0.80
   Heavy areas               0.60-0.90
Industrial
   Railroad yard areas         0.20-0.40
   Unimproved areas          0.10-0.30
Streets
   Asphaltic                  0.70-0.95
   Concrete                   0.80-0.95
     Brick                      0.70-0.85
     Drives and walks           0.70-0.85
     Roofs                     0.75-0.95
  Lawns: Sandy Soil
     Flat, 2 percent              0.05-0.10
     Average, 2-7 percent       0.10-0.15
     Steep, 7 percent            0.15-0.20
  Lawns: Heavy Soil
     Flat, 2 percent              0.13-0.17
     Average, 2-7 percent       0.18-0.22
     Steep, 7 percent            0.25-0.35
You should choose the most appropriate runoff coefficient for your site or calculate a weighted-average
coefficient, which takes into account different types of land use at your facility:
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Weighted-average runoff coefficient =
  (Area 1 % of total)(Cl) + (Area 2 % of total)(C2) + (Area 3 % of total)(C3) + ... + (Area i % of total)(Ci)
  where

  Ci =   runoff coefficient for a specific land use of Area i.
  Example 13: Stormwater Runoff

  Your facility is located in a semi-arid region of the United States that has  an annual precipitation
  (including snowfall) of 12 inches of rain. (Snowfall should be converted to the equivalent inches of rain;
  assume one foot of snow is equivalent to one inch of rain.) The total area covered by your facility is 42
  acres (about 170,000 square meters or 1,829,520 square feet). The area of your facility is 50 percent
  unimproved area, 10 percent asphaltic streets, and 40 percent concrete pavement.

  The total storm water runoff from your facility is therefore calculated as follows:
          Land Use            % Total Area
          Unimproved area          50
          Asphaltic streets           10
          Concrete pavement         40
                                Runoff
                                Coefficient
                                   0.20
                                   0.85
                                   0.90
  Weighted-average runoff coefficient = [(50%) x (0.20)] + [(10%) x (0.85)] + [(40%) x (0.90)] = 0.545
   (Rainfall) x (land area) x (conversion factor) x (runoff coefficient) = Stormwater runoff
       (1 ft/year) x (1,829,520 ft2) x (7.48 gal/ft3) x (0.545) = 7,458,222 gallons/year
   Total Stormwater runoff = 7,458,222 gallons/year
  Your Stormwater  monitoring data shows that the average concentration of zinc in the Stormwater runoff
  from your  facility from a biocide  containing a zinc compound is  1.4 milligrams per liter. The total
  amount of zinc discharged to surface water through the plant wastewater discharge (non-stormwater) is
  250 pounds per year. The total amount of zinc discharged with Stormwater is:
       (7,458,222 gallons stormwater)x(3.785 liters/gallon) = 28,229,370 liters Stormwater
       (28,229,370 liters stormwater)x(1.4 mg zinc/liter) x 103 g/mg x (1/454) Ib/g = 87 Ib zinc.

  The total amount of zinc discharged from all sources of your facility is:

                 250 pounds zinc from wastewater discharged
                +87 pounds zinc from Stormwater runoff
                337 pounds zinc total water discharged

  The percentage of zinc discharge through Stormwater reported in section 5.3 column C on Form R is:

                        (87/337)xlOO% = 26%
Section 6.    Transfers of the EPCRA
               Section 313 Chemical in
               Wastes to Off-Site Locations
You must  report in this section the total  annual
quantity  of the  EPCRA Section 313 chemical  in
wastes sent to any off-site facility for the purposes
of  disposal,   treatment,  energy   recovery,   or
recycling. Report the total amount of the EPCRA
                             Section 313  chemical transferred off-site after any
                             on-site waste treatment,  recycling,  or removal is
                             completed.

                             For all  toxic  chemicals (except the  dioxin  and
                             dioxin-like compounds category), do not enter the
                             values in Section 6 in gallons,  tons, liters, or any
                             measure other than pounds. You must also enter the
                             values  as  whole  numbers. Numbers  following  a
                             decimal point are not acceptable for toxic chemicals
   46
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
other than those designated as PBT chemicals. For
PBT chemicals, facilities should report release and
other waste management quantities greater than 0.1
pound   (except  the   dioxin   and   dioxin-like
compounds category) provided the accuracy and the
underlying  data on which the  estimate  is  based
supports this level of precision. For the dioxin and
dioxin-like  compounds  category,  facilities  should
report  at a level of  precision supported by the
accuracy of the underlying data and the estimation
techniques  on  which  the  estimate  is  based.
However, the smallest quantity that need be reported
on  the  Form  R for  the dioxin and  dioxin-like
compounds category is 0.0001 grams (see Example
12). Notwithstanding  the  numeric precision  used
when determining reporting  eligibility thresholds,
facilities  should report on Form  R to  the level of
accuracy that their data supports, up to seven digits
to the right of the decimal. EPA's reporting software
and  data  management  systems  support  data
precision to seven digits to the right of the decimal.

NA vs. a Numeric Value (e.g.,  Zero). You  must
enter a numeric value if you transfer an EPCRA
Section 313 chemical to a POTW or transfer wastes
containing  that  toxic  chemical  to  other off-site
locations. If the aggregate amount transferred was
less  than 0.5  pound,  then you should enter zero
(unless the  chemical is listed as a PBT chemical).
Also report zero for transfers of listed mineral acids
(i.e., hydrogen fluoride and nitric acid) if they have
been neutralized to a pH of 6 or above prior to
discharge to a POTW; do not check NA.

However, if  you do  not  discharge wastewater
containing  the  reported  EPCRA  Section   313
chemical to a  POTW, you should enter NA in the
box for the  POTW's name in Section 6.1.B._ If you
do  not ship  or transfer wastes  containing  the
reported EPCRA Section 313 chemical to  other off-
site locations,  you should enter NA  in the box for
the off-site location's EPA Identification Number in
Section 6.2._.

Important:  You  must number the  boxes  for
reporting the information for  each POTW or other
off-site location in Sections 6.1 and 6.2. In  the upper
left hand corner of each box, the  section number is
either 6.1.B._. or 6.2._.

If you report a transfer of the listed EPCRA Section
313 chemical to one or more POTWs, you should
number the boxes  in  Section  6.1.B  as  6.I.B.I,
6.1.B.2, etc. If you transfer the EPCRA Section 313
 chemical to more  than  two POTWs, you  should
 photocopy  Page  3  of Form R  as many  times  as
 necessary and then  number the boxes consecutively
 for each POTW. At the bottom of Part II Section 6.1
 of the  Form  R  you  will  find  instructions  for
 indicating the total  number of pages numbered "3"
 that you are submitting as part of Form R, as well as
 indicating   the  sequence  of  those  pages.  For
 example, your facility transfers the reported EPCRA
 Section  313  chemical  in  wastewaters  to  three
 POTWs. You would  photocopy  Page  3  once,
 indicate  at the bottom of each Page 3 that there are a
 total of  two pages numbered "3" and then indicate
 the first and second Page 3. The boxes for the two
 POTWs on the first Page 3 should be numbered
 6.I.B.I and 6.1.B.2, while the box for third POTW
 on the second Page  3 should be numbered 6.I.B.3.

 If you report a transfer of the EPCRA Section 313
 chemical to one or more other off-site locations, you
 should number the boxes in section  6.2  as 6.2.1,
 6.2.2, etc.  If you transfer the EPCRA  Section 313
 chemical to more than two other off-site locations,
 you should photocopy Page 4 of Form  R as many
 times as necessary and then  number the boxes
 consecutively  for  each  off-site  location. At  the
 bottom  of  Page  4 you  will find instructions  for
 indicating the total  number of Page 4s that you are
 submitting  as  part of  the  Form  R  as  well  as
 indicating   the  sequence  of  those  pages.  For
 example, your facility transfers the reported EPCRA
 Section  313   chemical  to  three  other  off-site
 locations.  You should  photocopy page  4  once,
 indicate  at the bottom of Section 6.2 on each Page 4
 that  there  are  a total  of two  Page  4s and then
 indicate  the first and second Page 4. The boxes for
 the two  off-site locations on the first Page 4 would
 be numbered 6.2.1  and 6.2.2, while the box  for the
 third off-site location on the  second Page  4  should
 be numbered 6.2.3.

6.1      Discharges to Publicly Owned Treatment
        Works
 In  Section 6.1.A,   estimate  the quantity  of  the
 reported EPCRA Section 313 chemical transferred
 to all POTWs and the basis upon which the estimate
 was made.  In Section 6.I.E., you should  enter the
 name and  address  for each POTW to which your
 facility discharges or otherwise transfers wastewater
 containing  the  reported  EPCRA  Section  313
 chemical. The  most common transfers of this type
 will be conveyances of the toxic chemical in facility
 wastewater through  underground  sewage  pipes;
 however,  materials  may  also be  trucked   or
                      Toxics Release Inventory Reporting Forms and Instructions
                                             47

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transferred via some  other  direct methods  to a
POTW.

If you do not discharge wastewater containing  the
reported EPCRA Section 313 chemical to a POTW,
enter NA in the box for the POTW's name in
Section  6.1.B._  (See discussion of  NA  vs. a
Numeric Value (e.g., Zero) in the introduction of
Section 6).
6.1.A.1 Total Transfers
Enter the total amount, in pounds, of the reported
EPCRA Section 313 chemical that is contained in
the wastewaters  transferred to all POTWs. Do not
enter the total poundage of the wastewaters. If the
total amount transferred is less than  1,000 pounds,
you may report a range by entering the appropriate
range code (range reporting in section 6.I.A.I does
not  apply   to  PBT  chemicals).  The   following
reporting range codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
1-10
11-499
500-999
6. LA. 2 Basis of Estimate
You must identify the basis for your estimate of the
total quantity of the reported EPCRA Section 313
chemical  in the  wastewater  transferred  to  all
POTWs. You should enter one of the  following
letter codes that applies to the method by  which the
largest percentage of the estimate was derived.

Ml  Estimate is based on continuous monitoring
     data or measurements for the EPCRA  Section
     313 chemical.
M2  Estimate  is  based on  periodic  or  random
     monitoring  data or  measurements  for the
     EPCRA Section 313 chemical.
C    Estimate   is   based   on   mass    balance
     calculations, such as calculation of the  amount
     of the EPCRA Section  313  chemical in
     streams   entering   and   leaving    process
     equipment.
El   Estimate  is  based  on  published  emission
     factors, such as those relating release quantity
     to  through-put or equipment type  (e.g., air
     emission factors).
E2   Estimate is based  on-site specific emission
     factors, such as those relating release quantity
     to  through-put or equipment type  (e.g., air
     emission factors).
                                    O    Estimate is based on other approaches such as
                                          engineering  calculations  (e.g.,  estimating
                                          volatilization  using published mathematical
                                          formulas) or best engineering judgment. This
                                          would include applying an estimated removal
                                          efficiency  to a waste stream,  even  if  the
                                          composition of the stream before  treatment
                                          was fully identified through monitoring data.

                                    If you transfer an EPCRA Section 313 chemical to
                                    more than one POTW, you  should report the basis
                                    of estimate that was used to determine the  largest
                                    percentage of the EPCRA Section 313 chemical that
                                    was transferred.
                                    6.2
       Transfers to Other Off-Site Locations
In Section 6.2 enter the EPA Identification Number,
name,  and address  for  each off-site  location to
which  your  facility  ships  or  transfers  wastes
containing  the  reported  EPCRA  Section  313
chemical for the purposes of disposal, treatment,
energy recovery, or recycling. Also  estimate the
quantity  of  the  reported  EPCRA  Section  313
chemical transferred  and the basis upon which the
estimate was made. This would include any residual
chemicals in "empty" containers transferred off-site.
EPA expects that all  containers (bags, totes, drums,
tank trucks,  etc.)  will have a  small amount of
residual solids and/or liquids. Please see Example
14 for residue  quantities  left in  drums and tanks
when emptied.

If appropriate, you must report multiple activities
for each off-site location.  For  example, if your
facility  sends  a reported  EPCRA  Section  313
chemical in a single waste  stream to an  off-site
location where  some of the EPCRA  Section  313
chemical is to be recycled while  the remainder of
the quantity transferred is to be treated,  you must
report  both  the  waste  treatment  and  recycle
activities, along  with the  quantity associated with
each activity.

If your facility transfers an EPCRA  Section  313
chemical to an  off-site location  and  that  off-site
location performs more than four activities  on  that
chemical, provide the necessary information in Box
6.2.1  for  the off-site  facility  and the  first four
activities. Provide the information on the remainder
of the activities in Box 6.2.2 and provide again the
off-site   facility   identification   and   location
information.
   48
        Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
If you do not ship or transfer wastes containing the
EPCRA  Section  313  chemical  to other off-site
locations, you should enter NA (See discussion of
NA  vs.  a  Numeric Value  (e.g.,  Zero) in  the
introduction of Section  6) in the box for the off-site
location's EPA Identification Number (defined in 40
CFR 260.10 and therefore commonly referred to as
the RCRA ID Number). This number may be found
on the Uniform Hazardous Waste Manifest, which is
required  by  RCRA  regulations.  If you ship  or
transfer wastes containing an EPCRA Section 313
chemical and the off-site  location does not have an
EPA Identification Number (e.g., it does not accept
RCRA hazardous wastes) enter NA in the box for
the off-site location EPA Identification  Number. If
you ship or transfer hazardous wastes containing an
EPCRA  Section 313 chemical to  a facility that
treats, stores, or disposes RCRA hazardous wastes,
make  sure   to  include  that  facility's RCRA
Identification Number  in the box  for the off-site
location EPA Identification Number. This RCRA ID
is shown  on  the  RCRA  manifest  that  must
accompany  the  hazardous waste  to  the off-site
facility.

If you ship or transfer the reported EPCRA Section
313 chemical in wastes to another country, you do
not need  to report a RCRA ID for that  waste. You
should indicate NA in the RCRA ID field. Enter the
complete address of the non-U.S. facility in the off-
site address fields, the city in the city field, the non-
U.S.  state or province in the county field, the postal
code in the zip code field, and the foreign country
code in the country field. The most commonly used
FIPs codes are listed in Table IV. To obtain a FIPS
code  for  a country not listed, contact  the TRI
Information Center.  There is nothing to enter  in the
state field.

6.2a   Column A: Total Transfers
For each off-site location, enter the total amount, in
pounds (in  grams  for  dioxin  and  dioxin-like
compounds),  of the EPCRA Section 313  chemical
that  is contained in the waste  transferred to that
location. Do  not enter the total quantities of the
waste.  If  you do  not ship  or  transfer wastes
containing  the  EPCRA Section 313 chemical  to
other off-site locations, you should enter  NA (See
discussion of NA vs. a Numeric Value (e.g.,  Zero)
in the introduction of Section 6) in the box for the
off-site location's  EPA   Identification  Number
(defined in 40 CFR 260.10 and therefore commonly
referred to as the RCRA ID Number).

If the  total amount transferred  is  less than  1,000
pounds, you  may report a range by entering  the
appropriate range code (range reporting in section
6.2   does   not  apply  to   PBT chemicals).  The
following reporting range codes are to be used:
Code
A
B
C
Reporting Range (in pounds)
       1-10
       11-499
       500-999
                      Toxics Release Inventory Reporting Forms and Instructions
                                            49

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                Summary of Residue Quantities From Pilot-Scale Experimental Studya'b
                                   (weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined
tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244
0.472
0.404
0.032
0.080
0.054
0.020
0.039
0.033
0.031
0.042
0.038
0.024
0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266
0.458
0.403
0.026
0.039
0.034
0.016
0.024
0.019
0.033
0.034
0.034
0.020
0.040
0.033
Motor Oile
1.97-2.23
2.06
1.70-3.48
2.30
0.677
0.787
0.737
0.328
0.368
0.350
0.100
0.121
0.111
0.133
0.191
0.161
0.112
0.134
0.127
Surfactant
Solution'
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
aFrom "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental Protection Agency,
Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30, 1986.
b The values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid materials. At
viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information on this table is not applicable.
°For kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
eFor motor oil, viscosity = 94 centipoise, surface tension = 34.5 dynes/cm2
fFor surfactant solution, viscosity = 3 centipoise, surface tension =31.4 dynes/cm2
  Example 14: Container Residue

  You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
  purchases and uses one thousand 55-gallon steel drums that contain a 10 percent solution of the chemical.
  Further, it is assumed that the physical properties of the  solution are similar to water. The solution  is
  pumped from the drums  directly  into a mixing vessel and the "empty" drums are triple-rinsed with water.
  The rinse water is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.

  In this example, it can be assumed that all of the residual solution in the drums was transferred to the rinse
  water. Therefore, the quantity transferred to the drum reclaimer should be  reported as "zero." The annual
  quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the mean
  weight percent of residual solution remaining in water from pumping a steel drum (2.29 percent from the
  preceding  table, "Summary of Residue Quantities From Pilot-Scale Experimental Study")  by the total
  annual weight of solution in the drum (density of solution multiplied by drum volume). If the density is not
  known, it may be appropriate to use the density of water  (8.34 pounds per gallon):

      (2.29%) x (8.34 pounds/gallon) x (55 gallons/drum) x (1,000 drums) =  10,504 pounds solution
   50
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
 The concentration of the EPCRA Section 313 chemical in the solution is only 10%.

      (10,504 pounds solution) x (10%) = 1,050 pounds

 Therefore, 1,050 pounds of the chemical are transferred to the POTW.
 Example 15:  Reporting  Metals  and Metal
 Category Compounds that are sent Off-site

 A facility manufactures a product containing
 elemental  copper,  exceeding  the processing
 threshold for copper.  Various metal fabrication
 operations for the process produce a wastewater
 stream that contains some  residual copper and
 off-specification    copper    material.    The
 wastewater  is collected and  sent  directly to a
 POTW. Periodic monitoring data show that 500
 pounds of copper were transferred to the POTW
 in the reporting  year. The POTW eventually
 releases  these chemicals to a stream. The off-
 specification products (containing  copper) are
 collected and sent off-site to a RCRA Subtitle C
 landfill.  Sampling analyses  of  the  product
 combined with hazardous waste  manifests were
 used to determine that 1,200 pounds of copper
 in the off-spec product were sent to the off-site
 landfill.

 Therefore, the facility must report 500 pounds  in
 Sections 6.1  and 8.Id,  and  1200 pounds  in
 Sections 6.2 (waste code M65 (RCRA Subtitle
 C Landfill) should be used) and 8.Id.

 Note  that for EPCRA  Section  313 chemicals
 that  are  not   metals   or  metal  category
 compounds, the quantity sent for treatment  at
 POTWs  and to other off-site treatment locations
 must  be  reported in  Section  8.7 -  Quantity
 Treated  Off-site. However, if you know that
 some or all of the chemical is  not treated for
 destruction  at  the off-site location you  must
 report that quantity in Section 8.1.
If you transfer the EPCRA Section 313 chemical in
wastes to an off-site facility for distinct and multiple
purposes, you must report those activities for each
off-site  location,  along with the  quantity of  the
reported EPCRA  Section 313 chemical associated
with  each  activity. For  example,  your  facility
transfers a total of 15,000 pounds of toluene to an
off-site  location that will use 5,000  pounds for the
purposes  of energy  recovery,  will  enter  7,500
pounds  into  a recovery process, and will dispose of
the remaining  2,500 pounds. These quantities and
the associated  activity codes  must  be  reported
separately in  Section  6.2.  (See Figure  4  for  a
hypothetical Section  6.2 completed for two off-site
locations, one of which receives  the transfer of
15,000 pounds of toluene as detailed.) If you have
fewer  than  four total transfers in  Section 6.2
Column A (see examples in Figure 4), an NA should
be placed in Column A of the first unused row to
indicate the  termination of the sequence. If all four
rows are  used, there is no  need to terminate the
sequence. If there are more than four total transfers,
re-enter the  name of the  off-site location, address,
etc. in the next row (6.2.2)  and then you should
enter NA when the sequence has terminated if there
are fewer than 8 (i.e. anytime there are fewer than 4
transfers listed in  a Section 6.2 block, an NA should
be used to terminate the sequence).

Do not double or multiple count amounts transferred
off-site.  For example, when  a reported EPCRA
Section 313 chemical is sent to  an  off-site facility
for sequential activities, you should  report the final
disposition of the toxic chemical.

6.2b    Column B: Basis of Estimate
You must identify the basis for your estimates of the
quantities of the reported  EPCRA  Section  313
chemical  in waste  transferred to  each off-site
location. Enter one of the  following letter codes that
applies  to  the   method  by  which the  largest
percentage of the estimate was derived.

Ml  Estimate is based on  continuous monitoring
     data or measurements for the EPCRA Section
     313 chemical.
M2  Estimate  is based  on periodic or random
     monitoring  data or  measurements for the
     EPCRA Section 313 chemical.

C    Estimate    is   based   on  mass   balance
     calculations,  such   as  calculation of the
                      Toxics Release Inventory Reporting Forms and Instructions
                                             51

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      amount of the EPCRA Section 313 chemical
      in  streams  entering  and  leaving  process
      equipment.
El    Estimate  is  based  on  published  emission
      factors, such as those relating release quantity
      to through-put or equipment type  (e.g., air
      emission factors).
E2    Estimate is based on  site specific emission
      factors, such as those relating release quantity
      to through-put or equipment type  (e.g., air
      emission factors).
O    Estimate is based on other approaches such as
      engineering  calculations  (e.g.,   estimating
      volatilization using  published mathematical
      formulas) or best engineering judgment. This
      would include applying an estimated removal
      efficiency  to a waste  stream,  even if the
      composition  of the  stream  before treatment
      was fully identified through monitoring data.

6.2c   Column C: Type of Waste Management:
       Disposal/ Treatment/Energy
       Recovery/Recycling
You should enter one of the following M codes to
identify the type  of disposal, treatment,  energy
recovery, or recycling methods used by the off-site
location  for the  reported EPCRA Section 313
chemical. You must use more than one line and
code for a single  location when distinct quantities of
the  reported EPCRA  Section  313  chemical  are
subject to  different waste management activities,
including disposal, treatment, energy recovery,  or
recycling. You must use the code that represents the
ultimate disposition of the chemical.

If the EPCRA Section 313 chemical is sent off-site
for further direct reuse (e.g., an EPCRA Section 313
chemical in  used solvent that will  be  used  as
lubricant at another facility) and does not undergo a
waste management activity (i.e., release (including
disposal), treatment, energy recovery, or recycling
(recovery))   prior to that reuse,  it need not be
reported in section 6.2 or section 8.

Incineration vs. Energy Recovery

You must distinguish between incineration which is
waste treatment, and legitimate energy recovery. For
you to claim that  a reported EPCRA Section 313
chemical sent off-site is used  for the purposes  of
energy  recovery  and   not  for  treatment  for
destruction, the EPCRA Section 313 chemical must
have  a significant heating  value  and  must be
combusted  in an energy recovery unit such as an
                            industrial boiler, furnace,  or  kiln.  In a situation
                            where the reported EPCRA Section 313 chemical is
                            in a waste that is combusted in an energy recovery
                            unit, but the EPCRA Section 313 chemical does not
                            have  a  significant heating value, e.g., CFCs, you
                            should  use  code M54,  Incineration/Insignificant
                            Fuel Value, to indicate that the EPCRA Section 313
                            chemical was incinerated in an energy recovery unit
                            but did not  contribute to  the heating value of the
                            waste.

                            Metals and Metal Category Compounds

                            Metals  and metal category compounds  will  be
                            managed  in  waste  either   by being  released
                            (including  disposed)   or  by   being  recycled.
                            Remember  that  the  release  and   other  waste
                            management information that you report for metal
                            category compounds will be the total  amount of the
                            parent metal  released or recycled  and NOT the
                            whole metal category compound.  The metal has  no
                            heat value and thus cannot be combusted for energy
                            recovery and cannot be treated because it cannot be
                            destroyed. Thus,  transfers  of metals  and  metal
                            category compounds for further waste management
                            should be reported as either a transfer for recycling
                            or  a  transfer  for disposal.  The  applicable  waste
                            management codes for transfers of metals and metal
                            category compounds for recycling are M24, metals
                            recovery, M93,  waste broker - recycling, or M26,
                            other reuse/recovery. Applicable codes for transfers
                            for disposal include M10, M41, M62, M64, M65,
                            M66, M67, M73, M79, M81, M82, M90, M94, and
                            M99. These  codes  are for off-site  transfers for
                            further  waste   management in  which  the  waste
                            stream may be treated but the metal contained in the
                            waste  stream   is  not treated  and  is  ultimately
                            released. For example, M41 should  be  used for a
                            metal or metal category compound that is stabilized
                            in preparation for disposal.

                            Applicable codes for Part II, Section  6.2, column C
                            are:

                            Disposal
                            M10    Storage Only
                            M41    Solidification/Stabilization - Metals and
                                    Metal  Category Compounds only
                            M62    Wastewater Treatment (Excluding POTW) -
                                    Metals and Metal Category Compounds only
                            M64    Other Landfills
                            M65    RCRA Subtitle C Landfills
                            M66    Subtitle C Surface  Impoundment
                            M67    Other Surface Impoundments
                            M73    Land Treatment
                            M79    Other Land Disposal
   52
Toxics Release Inventory Reporting Forms and Instructions

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                         Instructions for Completing Part II of EPA Form R
M81   Underground Injection to Class I Wells
M82   Underground Injection to Class II-V Wells      Energy Recovery
M90   Other Off-Site Management                  M56   Energy Recovery
M94   Transfer to Waste Broker - Disposal           M92   Transfer to Waste Broker - Energy
M99   Unknown                                         Recovery

Treatment                                         Recycling
M40   Solidification/Stabilization                   M20   Solvents/Organics Recovery
M50   Incineration/Thermal Treatment               M24   Metals Recovery
M54   Incineration/Insignificant Fuel Value           M26   Other Reuse or Recovery
M61   Wastewater Treatment (Excluding POTW)      M28   Acid Regeneration
M69   Other Waste Treatment                       M93   Transfer to Waste Broker - Recycling
M95   Transfer to Waste Broker - Waste
       Treatment
                      Toxics Release Inventory Reporting Forms and Instructions                   53

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SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.1
Off-Site EPA Identification Number (RCRA No.)

Off-Site Location Name

Street Address

City

State


Acme V

UULttbb 16241
/aste Services
51

Market Street
Anywhere
CO

Zip Code

A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
3.
4.
5,000
7,500
2,500
NA




Co

unty
Hill

or\Af. i 's location under control of reporting r—i „ rjn NO
01/40 1 facility or parent company
(enter code)
l.O
2.C
3.0
4.
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M56
2 M20
~ MOD
4. M
This off-site location receives a transfer of 15,000 pounds of toluene and will combust 5,000 pounds for the
purposes of energy recovery,  will enter  7,500  pounds into  a recovery process, and will  dispose of the
remaining 2,500 pounds.
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATION
6.2.2
Off-Site EPA Identification Number (RCRA No.)

Off-Site Location Name „ ,
I VkTviKno


Street Address _
O« T7o~l1l+rr T>™

City
State

Dumfiy
f-,f^ Z'P Code

A. Total Transfers (pounds)/year)
(enter range code or estimate)
1.
2.
12,500
NA
3.
4.
UUU10/72M.32
tion, Inc.
id
County





Buins
en^nn Is location under control of reporting •— | YHS FX1 No
80500 facility or parent company L- ' Yes ^

1. O
2.
3.
4.
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
j M54
2. M
3. M
4. M
This off-site location receives a transfer of 12,500 pounds of tetrachloroethylene (perchloroethylene) that is
part of a waste that is combusted for the purposes of energy recovery in an industrial furnace. Note that the
tetrachloroethylene should be reported using code M54 to indicate that it is combusted in an energy recovery
unit but it does not contribute to the heating value of the waste.

            Figure 4. Hypothetical Section 6.2 Completed for Two Off-Site Locations
   54
Toxics Release Inventory Reporting Forms and Instructions

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                         Instructions for Completing Part II of EPA Form R
Section 7.   On-Site Waste Treatment,
              Energy Recovery, and
              Recycling Methods

You must report in this section the methods of waste
treatment, energy recovery, and recycling applied to
the reported EPCRA Section 313 chemical in wastes
on-site.   There  are  three  separate  sections  for
reporting such activities. (Section 7A column c and
Section  7A column e were previously deleted from
Form R and are not addressed below.)

Section  7A:   On-Site Waste Treatment
              Methods and Efficiency
Most of the chemical-specific information required
by EPCRA Section 313 that is reported  on Form R
is  specific  to the  EPCRA Section 313 chemical
rather than  the waste  stream containing the EPCRA
Section  313  chemical.  However, EPCRA  Section
313  does  require  that  waste treatment methods
applied  on-site to  waste  streams that contain the
EPCRA  Section 313 chemical be reported. This
information is reportable regardless of whether the
facility actively applies treatment or the treatment of
the waste stream occurs passively. This information
is collected in Section 7A of Form R.

In Section  7A, you must provide  the following
information if you treat waste streams containing
the reported EPCRA Section 313 chemical on-site:

(a)   The general waste stream types containing the
     EPCRA Section 313 chemical being reported;
(b)   The waste  treatment method(s) or sequence
     used  on all waste  streams  containing the
     EPCRA Section 313 chemical; and
(c)   The  efficiency  of  each  waste  treatment
     method  or  waste   treatment  sequence   in
     destroying  or removing the  EPCRA Section
     313 chemical.
7A Column a: General Waste Stream
For each waste treatment method, indicate the type
of waste stream containing the EPCRA Section 313
chemical that is  treated. Enter the letter code that
corresponds to the general waste stream type:

A  Gaseous (gases, vapors, airborne particulates)
W  Wastewater (aqueous waste)
L  Liquid waste streams (non-aqueous waste)
S   Solid waste streams  (including  sludges and
    slurries)

If a waste is a combination of water and organic
liquid  and the  organic content  is  less  than  50
percent, report it as a wastewater (W). Slurries and
sludges containing water should be reported as solid
waste  if  they   contain appreciable  amounts   of
dissolved solids,  or solids that may settle, such that
the viscosity or density of the waste is considerably
different from that of process wastewater.

7A Column b: Waste Treatment Method(s)
       Sequence

Enter the appropriate waste treatment code from the
list below for each on-site waste treatment method
used on a waste  stream  containing the EPCRA
Section 313 chemical, regardless of  whether the
waste  treatment  method   actually  removes the
specific  EPCRA  Section   313  chemical   being
reported. Waste treatment methods must be reported
for each type of waste  stream being  treated (i.e.,
gaseous waste  streams,  aqueous waste  streams,
liquid  non-aqueous waste streams,  and  solids).
Except  for the  air emission treatment codes, the
waste  treatment  codes  are  not restricted to any
medium.
Use a separate line in Section 7A for each general    Waste streams containing the EPCRA Section 313
waste stream type. Report only information about
treatment  of waste streams at your facility,  not
information about off-site waste treatment.

If you do not perform on-site treatment  of waste
streams containing the reported EPCRA Section 313
chemical,  check the NA box at the top of Section
7A.
chemical may have  a single  source  or may be
aggregates of many sources. For example, process
water from  several pieces  of equipment  at your
facility may be combined prior to waste treatment.
Report waste treatment methods that apply to  the
aggregate waste stream, as well as waste treatment
methods that apply to individual waste streams. If
your  facility  treats  various  wastewater  streams
containing the EPCRA  Section 313  chemical  in
different  ways,   the  different  waste  treatment
methods must be listed separately.	
                      Toxics Release Inventory Reporting Forms and Instructions
                                            55

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If your facility  has several  pieces  of equipment
performing a similar service  in  a waste treatment
sequence, you may combine the  reporting for such
equipment. It is not necessary to enter four codes to
cover four scrubber units, for example, if all four are
treating waste streams  of similar character  (e.g.,
sulfuric acid mist emissions), have similar influent
concentrations,    and   have    similar   removal
efficiencies. If, however,  any of these  parameters
differs from  one unit  to  the  next, each  scrubber
should be listed separately.

If you are using the hardcopy paper form, and if
your facility  performs  more  than eight sequential
waste treatment methods on a single general waste
                             stream, continue listing the methods in the next row
                             and renumber appropriately those waste treatment
                             method  code boxes  you used to  continue  the
                             sequence. For example, if the  general waste stream
                             in box VA.la had nine treatment methods applied to
                             it, the ninth method would be indicated in the first
                             method box for row 7A.2a. The numeral "1" would
                             be crossed out, and a "9" would be inserted.

                             Treatment applied to any other general waste stream
                             types would then be listed in the next empty row. In
                             the scenario below, for instance, the second general
                             waste stream would be reported in row 7A.3a. See
                             Figure 5  for an example  of a hypothetical section
                             7A.
   56
Toxics Release Inventory Reporting Forms and Instructions

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                        Instructions for Completing Part II of EPA Form R
Example 16: Calculating Releases and Other Waste Management Quantities

Your facility disposes of 14,000 pounds of lead chromate (PbCrCH.PbO) in an on-site landfill and transfers
16,000 pounds of lead selenite (PbSeO4) to  an off-site  land disposal facility. You would therefore be
submitting three separate reports on the following: lead compounds, selenium compounds, and chromium
compounds. However, the quantities you would be reporting would be the pounds of "parent" metal being
released on-site or transferred off-site for further waste  management. All quantities are based on  mass
balance calculations (See Section 5, Column B for information on Basis of Estimate and Section 6.2,
Column C for waste management codes and information on transfers of EPCRA Section 313 chemicals in
wastes). You would calculate releases of lead, chromium, and selenium by first determining the percentage
by weight of these metals in the materials you use as follows:

Lead Chromate (PbCrO4.PbO)                            Molecular weight = 546.37
     Lead (2 Pb atoms)                             Atomic weight = 207.2 x 2 = 414.4
     Chromium (1 Cr atom)                                   Atomic weight = 51.996

     Lead chromate is therefore (percent by weight)
                                    (414.4/546.37) =  75.85% lead and
                                    (51.996/546.37) = 9.52% chromium

Lead Selenite (PbSeO4)                                   Molecular weight = 350.17
     Lead (1 Pb atom)                                         Atomic weight = 207.2
     Selenium (1 Se atom)                                      Atomic weight = 78.96

     Lead selenite is therefore (percent by weight)
                                    (207.2/350.17) = 59.17% lead and
                                    (78.96/350.17) = 22.55% selenium.

The total pounds of lead, chromium, and selenium disposed on or off-site from your facility are as follows:
Lead
Disposal on-site:                      0.7585 x 14,000 = 10,619 pounds from lead chromate
Transfer off-site for disposal:          0.5917 x 16,000 = 9,467 pounds from lead selenite

Chromium
Disposal on-site:                      0.0952 x 14,000 = 1,333 pounds from lead chromate

Selenium
Transfer off-site for disposal:          0.2255 x 16,000 = 3,608 pounds from lead selenite
                    Toxics Release Inventory Reporting Forms and Instructions                    57

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                               Figure 5. Hypothetical Section 7A
Waste Treatment Codes
A01  Flare
A02  Condenser
A03  Scrubber
A04  Absorber
A05  Electrostatic Precipitator
A06  Mechanical Separation
A07  Other Air Emission Treatment
H040 Incineration—thermal destruction other than
      use as a fuel
H071 Chemical  reduction with or without
      precipitation
H073 Cyanide destruction with or without
      precipitation
H075 Chemical  oxidation
H076 Wet air oxidation
H077 Other chemical precipitation with or without
      pre-treatment
H081 Biological treatment with or without
      precipitation
H082 Adsorption
HO 8 3 Air or steam stripping
H101 Sludge treatment and/or dewatering
HI03 Absorption
Hill Stabilization or chemical fixation prior to
      disposal
HI 12 Macro-encapsulation prior to disposal
H121 Neutralization
HI22 Evaporation
HI23 Settling or clarification
HI24 Phase separation
HI29 Other treatment
                            7A Column d: Waste Treatment Efficiency
                                  Estimate
                            In the space provided, enter the range code, based
                            upon  the  codes  listed  below,  indicating   the
                            percentage  of the  EPCRA  Section 313  chemical
                            removed from the waste stream through destruction,
                            biological degradation,  chemical  conversion,  or
                            physical removal.  The waste treatment  efficiency
                            (expressed as a range of percent removal) represents
                            the percentage of the EPCRA Section 313 chemical
                            destroyed or removed (based on  amount or mass),
                            not merely changes in volume or concentration of
                            the EPCRA  Section 313  chemical  in the waste
                            stream. The efficiency, which can reflect the overall
                            removal from sequential treatment methods applied
                            to the general waste stream,  refers  only  to  the
                            percent  destruction,  degradation,  conversion,  or
                            removal of the EPCRA Section 313 chemical from
                            the waste  stream;  it  does  not  refer to the percent
                            conversion or removal of  other constituents in the
                            waste stream. The  efficiency also does not refer to
                            the general efficiency of the treatment method for
                            any  waste  stream.  For  some  waste  treatment
                            methods, the percent removal will represent removal
                            by  several  mechanisms, as  in an aeration basin,
                            where  an  EPCRA  Section 313  chemical  may
                            evaporate, biodegrade,  or be  physically  removed
                            from the sludge.
   58
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
Percent removal can be calculated as follows:
               g-E)xioo%
               i
where:
I =  amount of the EPCRA Section 313 chemical in
     the influent waste stream (entering the  waste
     treatment step or sequence) and
E =  amount of the EPCRA Section 313 chemical in
     the effluent  waste  stream (exiting  the  waste
     treatment step or sequence).

Calculate the amount of the  EPCRA Section 313
chemical in the influent waste stream by multiplying
the concentration (by weight) of the EPCRA Section
313  chemical in the waste  stream by  the total
amount or weight of the waste  stream. In most
cases,  the  percent removal  compares the treated
effluent to the influent  for the particular type  of
waste stream. For solidification of wastewater, the
waste treatment efficiency can be  reported as code
El  (greater than 99.9999 percent)  if no volatile
EPCRA Section 313 chemicals were removed with
the water or evaporated into the air. Percent removal
does not apply to incineration because  the  waste
stream, such as wastewater or  liquids, may not exist
in a  comparable form after waste treatment and the
purpose of incineration as a waste treatment is to
destroy the  EPCRA Section  313  chemical  by
converting  it to carbon dioxide and  water or other
byproducts. In cases where the EPCRA Section 313
chemical is incinerated, the percent efficiency must
be based on the amount of the EPCRA Section 313
chemical destroyed or combusted, except for metals
or metal category compounds. In the cases in which
a metal or metal category compound is incinerated,
the efficiency  is reported as code E6 (equal to or
greater than 0 percent, but less than or equal to 50
percent).

Similarly, an efficiency of zero must be reported for
any waste treatment method(s) that does not destroy,
chemically  convert  or  physically  remove  the
EPCRA  Section  313  chemical  from  the  waste
stream.

For metal category  compounds, the calculation of
the reportable concentration  and  waste treatment
efficiency must be based on the weight of the parent
metal,  not  on  the weight of the metal  compound.
Metals are  not destroyed, only physically removed
or chemically converted from one form into another.
The  waste  treatment  efficiency  reported  must
represent only physical removal of the parent metal
from the waste stream (except for incineration), not
the percent  chemical conversion  of  the  metal
compound. If a listed waste  treatment  method
converts but  does  not  remove  a metal  (e.g.,
chromium reduction), the method must be reported
with a waste treatment efficiency of code E6 (equal
to or greater than 0 percent, but less than or equal to
50 percent.

EPCRA  Section  313  chemicals that  are  strong
mineral acids neutralized to a pH of 6 or above are
considered treated at a 100 percent efficiency.

When   calculating   waste   treatment  efficiency,
EPCRA Section 313(g)(2) requires a facility to use
readily  available data (including monitoring data)
collected pursuant to other provisions of law, or,
where   such   data  are  not   readily   available,
"reasonable estimates" of the amounts involved.

Waste Treatment Efficiency Range Codes:

E1 =    greater than 99.9999%
E2 =    greater than 99.99%, but less than or equal
        to 99.9999%
E3 =    greater than 99%, but less than or equal to
        99.99%
E4 =    greater than 95%, but less than or equal to
        99%
E5 =    greater than 50%, but less than or equal to
        95%
E6 =    equal to or greater than 0%, but less than or
        equal to 50%

Section 7B On-site Energy Recovery Processes
In Section 7B, you must indicate the on-site energy
recovery methods  used on  the reported EPCRA
Section 313 chemical.

EPA considers an EPCRA Section 313 chemical to
be  combusted for energy  recovery if  the  toxic
chemical  has a  significant  heat  value  and  is
combusted in an  energy recovery  device. If  a
reported  EPCRA   Section   313   chemical   is
incinerated on-site but does not contribute energy to
the process (e.g., chlorofluorocarbons),  it must be
considered waste treated on-site and reported in
Section 7A. Metals and metal category compounds
cannot  be combusted for energy recovery  and
should NOT  be  reported in this section.  Do  not
include  the combustion of fuel oils, such as fuel oil
#6, in this section.  Energy recovery may take place
only in an industrial kiln, furnace, or boiler.
                      Toxics Release Inventory Reporting Forms and Instructions
                                            59

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NA vs. a Numerical Value (e.g., Zero). If you do
not perform  on-site  energy recovery for a waste
stream that  contains  or contained  the  EPCRA
Section 313 chemical, check the NA box at the top
of Section  7B and enter NA in Section  8.2.  If you
perform  on-site  energy  recovery  for  the  waste
stream that  contains  or contained  the  EPCRA
Section 313 chemical, enter the appropriate code in
Section  7B  and enter the appropriate value in
Section 8.2. If this quantity is  less than or equal to
0.5 pound, round to zero (unless the chemical is a
listed PBT chemical) and enter zero in  8.2.  (Note:
for metals  and  metal compounds, you should only
report NA in Sections 7B and Section 8.2.)

Energy Recovery Codes

U01   Industrial Kiln
U02   Industrial Furnace
U03   Industrial Boiler

If your facility uses more than one on-site energy
recovery  method for the  reported EPCRA Section
313 chemical, list the methods used in descending
order (greatest to least) based on the amount of the
EPCRA  Section  313   chemical  entering  such
methods.

Section 7C On-site Recycling Processes
In  Section  7C,  you  must report the  recycling
methods used on the EPCRA Section 313 chemical.

In this section,  use the codes below to report only
the recycling methods in  place at your facility that
are applied to the EPCRA Section 313  chemical. Do
not list any off-site recycling activities. (Information
about off-site recycling must be reported in Part II,
                             Section  6,  "Transfers of the  Toxic Chemical  in
                             Wastes to Off-site Locations.")

                             NA vs. a Numerical Value (e.g., Zero). If you do
                             not perform  on-site  recycling for  the  reported
                             EPCRA  Section 313 chemical, check the NA box at
                             the top of Section 7C and enter NA in Section 8.4. If
                             you perform  on-site  recycling for  the  reported
                             EPCRA  Section 313 chemical, enter the appropriate
                             code in Section 7C and enter the appropriate value
                             in Section 8.4. If this quantity is less than or equal to
                             0.5 pound, round to zero (unless the chemical is a
                             listed PBT chemical) and enter 0 in Section 8.4.

                             On-Site  Recycling Codes

                             H10  Metal  recovery (by retorting,  smelting,  or
                                  chemical or physical extraction
                             H20  Solvent   recovery   (including  distillation,
                                  evaporation, fractionation or extraction)
                                  Other  recovery or  reclamation for  reuse
H39
                                  (including acid regeneration or other chemical
                                  reaction process)
                             If your facility uses more than one on-site recycling
                             method for an EPCRA Section 313 chemical, enter
                             the codes in the space provided in descending order
                             (greatest  to  least) based  on the  volume  of the
                             reported EPCRA Section 313 chemical recovered by
                             each process. If your facility uses more than ten
                             separate methods for recycling the reported EPCRA
                             Section  313  chemical  on-site, then list the  ten
                             activities  that recover the greatest amount  of the
                             EPCRA Section 313 chemical (again, in descending
                             order).
   60
Toxics Release Inventory Reporting Forms and Instructions

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                          Instructions for Completing Part II of EPA Form R
Example 17: On-Site Waste Treatment

A process at the facility generates a wastewater stream containing an EPCRA Section 313  chemical (chemical A). A
second process generates a wastewater stream containing two EPCRA Section 313 chemicals,  a metal (chemical B) and a
mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of completing
separate Form Rs for each chemical.

These two wastewater streams are combined and sent to an on-site wastewater treatment system  before being discharged to
a POTW. This system consists of an oil/water separator that removes 99 percent of chemical A; a neutralization tank in
which the pH is adjusted to 7.5, thereby destroying 100 percent of the mineral acid (chemical C); and a settling tank where
95 percent of the metal (chemical B) is removed from the water (and eventually landfilled off-site).

Section 7A should be completed slightly differently when you file the Form R for each of the chemicals. The table
accompanying  this example shows how Section 7A should be completed for each chemical. First, on each FormR  you
should identify the type of waste stream in Section 7A.la as wastewater (aqueous waste, code W). Next, on each Form R
you should list the code for each of the treatment steps that is applied to the entire waste stream, regardless of whether the
operation affects the chemical for which you are completing the Form R (for instance, the first four blocks of Section 7A.lb
of all three Form Rs should show: H124 (phase separation), H121 (neutralization), H123 (settling or clarification), and N/A
(to signify the end of the treatment system). Note that Section 7A.lb is not chemical specific. It applies to the  entire waste
stream being treated. Section 7A.ld  applies  to the efficiency  of  the entire system in destroying and/or removing the
chemical for which you are preparing the Form R. You should enter E4 when filing for chemical A, E5 for chemical B, and
El for chemical C.

Chemical A
7A.la
W

7A.lb
3.H123
6.
1.H124
4. N/A
7.
2.H121
5.
8.
TA.ld
E4

Chemical B
TA.la
W

7A.lb
3.H123
6.
1.H124
4. N/A
7.
2.H121
5.
8.
TA.ld
E5

Chemical C
TA.la
W

TA.lb
3.H123
6.
1.H124
4. N/A
1.
2.H121
5.
8.
TA.ld
El

Note that the quantity removed and/or destroyed is not reported in Section 1 and that the efficiency reported in Section
TA.ld refers to the amount of EPCRA Section 313 chemical destroyed and/or removed from the applicable waste stream.
The amount actually destroyed should be reported in Sections.6 (quantity treated on-site). For example, when completing
the Form R for Chemical B you should report "N/A" pounds in Section 8.6 because the metal has been removed from the
wastewater stream, but not actually destroyed. The quantity of Chemical B that  is ultimately landfilled off-site  should be
reported in Sections 6.2  and 8.1c. However, when completing the Form  R for Chemical C  you should report  the entire
quantity in Section 8.6 because raising the pH to T.5 will completely destroy the mineral acid.
                     Toxics Release Inventory Reporting Forms and Instructions
61

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    Example 18: Reporting On-Site Energy Recovery

    One waste stream generated by your facility contains, among other chemicals, toluene and Freon 113.
    Threshold quantities are exceeded for both of these EPCRA Section 313 chemicals, and you would,
    therefore,  submit two separate Form R reports. This waste stream is sent to an on-site industrial
    furnace that uses the heat  generated in a thermal hydrocarbon cracking process  at your facility.
    Because toluene  has a significant heat value (17,440 BTU/pound) and the energy is recovered in an
    industrial furnace, the code "U02"  would be reported in Section 7B for the Form R submitted for
    toluene.

    However, as Freon 113 does not contribute any value for energy recovery purposes, the combustion of
    Freon 113 in the industrial  furnace is considered waste treatment, not energy recovery. You would
    report Freon 113 as  entering a waste treatment step (i.e., incineration), in Section 7A, column b. In
    Section 7B the facility should report zero.	
Section 8.   Source Reduction and
              Recycling Activities

This section includes the data elements mandated by
Section6607 of the Pollution Prevention Act of 1990
(PPA).

In Section  8, you must provide  information about
source reduction  activities and  quantities  of the
EPCRA Section 313 chemicals managed as waste.
For  all  appropriate  questions,  report only  the
quantity, in pounds,  of the reported EPCRA Section
313 chemical itself (except the dioxin and dioxin-
like compound category). Do not  include the weight
of water, soil,  or other waste constituents. When
reporting on  the  metal  category compounds,  you
should report only the amount of the metal portion
of the compound as  you do when estimating release
and other waste management amounts.

Sections 8.1 through 8.9 must be completed for each
EPCRA Section 313 chemical. Section 8.10 must be
completed only if a source reduction activity  was
newly implemented  specifically (in whole or in part)
for  the reported  EPCRA  Section  313 chemical
during the reporting  year. Section  8.11 allows you to
indicate if  you have  attached additional optional
information  on  source  reduction,  recycling,  or
pollution control activities implemented at any time
at your facility.

Sections  8.1   through  8.7  require  reporting  of
quantities for the  current reporting year, the  prior
year, and quantities anticipated in both the first year
immediately following the  reporting year and the
second year  following the reporting  year  (future
estimates).
                            Do not enter the values in Section 8 in gallons, tons,
                            liters, or any measure other than pounds. You must
                            also enter the values as whole numbers. Numbers
                            following a decimal  point are not acceptable  for
                            toxic chemicals other than those designated as PBT
                            chemicals.   For  PBT  chemicals facilities should
                            report   release  and  other   waste   management
                            quantities greater than 0.1  pound (except the dioxin
                            and dioxin-like compounds category) provided  the
                            accuracy and the  underlying data on  which  the
                            estimate is  based  supports this  level of precision.
                            For the dioxin and dioxin-like compounds category
                            facilities should   report  at  a  level  of precision
                            supported by the  accuracy of the underlying data
                            and the estimation  techniques on which the estimate
                            is based. However, the smallest quantity that need
                            be reported on the

                            Form R for the dioxin and dioxin-like compounds
                            category  is 0.0001  grams   (see  Example   12).
                            Notwithstanding the numeric precision used when
                            determining   reporting   eligibility   thresholds,
                            facilities should report on Form  R to the level of
                            accuracy that their data supports, up to seven digits
                            to the right of the decimal.  EPA's reporting software
                            and  data   management  systems   support  data
                            precision to seven digits to the right of the decimal.

                            NA vs. a Numeric Value (e.g., Zero). You should
                            enter a numeric value in the relevant sections of
                            Section  8  if your facility  has  released,  treated,
                            combusted  for energy  recovery or  recycled  any
                            quantity of an EPCRA Section 313 chemical during
                            the reporting year. If the aggregate quantity of that
                            toxic chemical was equal to or less than 0.5 pound
                            for a  particular waste  management method,  you
                            should enter the value zero (unless the chemical  is a
                            PBT chemical) in the relevant section.
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                          Instructions for Completing Part II of EPA Form R
However, if there has been no  on-site  or  off-site
treatment,  combustion  for  energy  recovery  or
recycling  on  the  waste   stream  containing  the
EPCRA  Section  313 chemical, then you  should
enter NA in the relevant section. (Note:  for metals
and  metal category compounds, you  should enter
NA  in Sections 8.2, 8.3, 8.6  and 8.7, as treatment
and  combustion for energy recovery generally are
not  applicable waste  management methods  for
metals and metal compounds). For Section 8.1b, NA
generally is not applicable  recognizing the potential
for spills, leaks, or fugitive emissions of the EPCRA
Section  313  chemical.  You  should enter  NA in
Section  8.8  if there were no  remedial actions,
catastrophic events  such as earthquakes, fires, or
floods or one time events not associated with normal
or routine production  processes  for  that toxic
chemical. If there was a catastrophic event  at your
facility,  but you were able to prevent any releases
from occurring, then enter zero in Section 8.8.

Column A: Prior Year

Quantities for  Sections 8.1 through  8.7 must be
reported for  the  year  immediately preceding the
reporting year in column A. For reports due July 1,
2009 (reporting year 2008), the prior year is 2007.
Information available at the  facility that may be
used to  estimate the prior  year's quantities  include
the prior year's  Form  R  submission,  supporting
documentation, and recycling,  energy  recovery,
treatment, or disposal  operating logs or invoices.
When reporting prior year estimates  facilities are
not  required   to  use quantities  reported  on  the
previous year's  form  if better  information is
available.

Column B: Current Reporting Year
Quantities for  Sections 8.1 through  8.7 must be
reported for the current reporting year in column B.

Columns C and D:  Following Year and Second
Following Year

Quantities for  Sections 8.1 through  8.7 must be
estimated  for  2009  and  2010.  EPA   expects
reasonable future  quantity  estimates using a logical
basis.  Information  available  at  the  facility  to
estimate quantities of the chemical expected during
these years  include  planned  source   reduction
activities, market projections, expected  contracts,
anticipated new  product  lines,  company  growth
projections,   and   production   capacity  figures.
Respondents  should take  into account protections
available for  trade secrets as provided in EPCRA
Section322  (42 USC  11042) for the  chemical
identity.

Relationship to Other Laws

The  reporting  categories  for  quantities  recycled,
used  for  energy  recovery, treated, and disposed
apply to completing Section 8 of Form R as well as
to the rest of Form R. These  categories are to be
used only for TRI reporting. They are  not intended
for  use   in  determining,  under  the Resource
Conservation and Recovery Act (RCRA) Subtitle C
regulations, whether a secondary material is a waste
when recycled.  These definitions also do not apply
to the information that may be submitted in the
Biennial Report required under RCRA. In addition,
these  definitions   do  not   imply  any   future
redefinition of RCRA terms and do not affect EPA's
RCRA authority or authority under any other statute
administered by EPA.

Differences  in   terminology   and   reporting
requirements  for  EPCRA  Section  313 chemicals
reported  on  Form  R and for hazardous  wastes
regulated under RCRA occur because  EPCRA and
the PPA  focus on specific chemicals, while the
RCRA regulations and the  Biennial Report focus on
waste streams  that may  include more than  one
chemical.  For example, a  RCRA hazardous waste
containing  an  EPCRA Section 313  chemical is
recycled  to recover  certain  constituents  of  that
waste, but not  the toxic chemical  reported under
EPCRA  Section  313. The  EPCRA  Section  313
chemical  simply  passes  through  the recycling
process  and  remains  in  the  residual from  the
recycling  process, which  is  disposed. While the
waste may be considered recycled under RCRA, the
EPCRA Section 313 chemical constituent would be
considered to be disposed for TRI purposes.

Quantities Reportable in Sections 8.1 - 8.7
Section 8 of Form R uses data collected to complete
Part  II,  Sections 5  through  7. For  this  reason,
Section  8 should be completed last. Sections  8.1,
8.3, 8.5, 8.7, and 8.8 use data collected to complete
Sections  5 and 6  of Form  R. The  relationship
between Section s 5, 6, and 8.8 to Sections 8.1, 8.3,
8.5, and 8.7 are  provided below in equation form.

Section 8.1. Beginning in  the  2003  reporting year,
Section 8.1 was divided into four Subsections (8.la,
8.1b, 8.1c  and  8.Id).  Please refer to the following
equations   that   show  the  relationship  between
Sections  5,  6  and  8.la  through  8.Id.  EPCRA
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Section 329(8)  defines  release as  "any spilling,
leaking,  pumping,  pouring,  emitting,  emptying,
discharging, injecting, escaping, leaching, dumping,
or  disposing   [on-site   or  off-site]   into   the
environment (including the abandonment of barrels,
containers,  and  other  closed  receptacles)."  In
Section 8.1,  facilities report disposal and  other
releases.  This includes  on-site disposal  and other
releases in Section 5 and off-site disposal and other
releases in Section  6 (releases plus  transfers to
disposal  and transfers to  POTWs of metals  and
metal compounds), but excludes quantities reported
in  Section 5  and  6  due  to  remedial  actions,
catastrophic  events,  or  non-production  related
events (see the discussion on Section 8.8).
 Example 19: Reporting Future Estimates

 A pharmaceutical manufacturing facility uses an
 EPCRA    Section   313   chemical   in   the
 manufacture  of a prescription drug. During the
 reporting year (2005), the  company received
 approval   from   the    Food    and   Drug
 Administration to begin marketing their product
 as an over-the-counter drug beginning in 2006.
 This approval  is publicly known and does not
 constitute confidential business information. As
 a result  of this expanded market, the company
 estimates that sales and subsequent production of
 this drug will increase their use of the reported
 EPCRA  Section 313 chemical by 30 percent per
 year for the  two years following the reporting
 year. The facility treats the EPCRA Section 313
 chemical on-site and the  quantity  treated is
 directly proportional to production activity. The
 facility thus  estimates the  total quantity of the
 reported  EPCRA Section 313  chemical  treated
 for the  following  year (2005) by adding  30
 percent to the amount in column  B (the amount
 for the  current  reporting  year).  The  second
 following year (2007) figure can be  calculated
 by adding an additional 30 percent to the amount
 reported   in  column  C (the  amount  for  the
 following year (2006) projection).
Metals and metal category compounds reported in
1)    Section    6.2   as    sent    off-site    for
stabilization/solidification    (M41Cmetals)     or
wastewater    treatment    (excluding    POTWs)
(M62Cmetals) and/or 2) in Section 6.1 - discharges
to POTWs, should be reported in Section 8.1. These
quantities should NOT be reported in Section 8.7
because the metals are ultimately disposed.
                             Sections 8.1a and 8.1b.  Toxic chemicals disposed
                             or otherwise released on-site are reported in 8. la or
                             8.1b as appropriate.  Toxic chemicals sent off-site
                             for disposal are reported in 8. Ic or 8. Id.

                             Section 8.1a = Section 5.4.1  + Section 5.5.1A +
                             Section 5.5.1B B  Section  8.8 (on-site  release  or
                             disposal due to catastrophic events)

                             Section 8.1b = Section 5.1  + Section 5.2 + Section
                             5.3  +  Section 5.4.2  +  Section  5.5.2  + Section
                             5.5.3A + Section 5.5.3B  + Section 5.5.4 - Section
                             8.8   (on-site  release  or   disposal    due   to
                             catastrophic events)

                             Sections 8.1c and 8.1d. Toxic chemicals transferred
                             off-site to POTWs or other off-site locations should
                             be reported  in 8.1c or  8.Id  as  appropriate. For
                             example, quantities of a toxic chemical sent to a
                             POTW  and  subsequently  sent to a landfill  are
                             reported in  Section  8.1c.  Quantities  of the  toxic
                             chemical  disposed  or  otherwise  released by  the
                             POTW  to a  stream are  reported  in Section  8.Id.
                             Metals  and  metal  category  compounds sent  to
                             POTWs should be reported in one of these two
                             sections and  should not be reported as  treated  for
                             destruction in Section 8.7.

                             Section 8.1c = Section  6.1 (portion of transfer
                             that is  untreated and ultimately disposed  of in
                             UIC Class I Wells, RCRA Subtitle C landfills,
                             and  other  landfills)  +  Section  6.2  (quantities
                             associated with M codes M64, M65 and M81) -
                             Section 8.8  (off-site disposal  due to catastrophic
                             events)

                             Section 8.1d = Section6.1 (portion of transfer that
                             is untreated and  ultimately  disposed  of in UIC
                             Class  II-V  wells,  and  disposal other  than  to
                             landfills) + Section 6.2 (quantities associated with
                             M codes M10, M41, M62, M66, M67, M73,  M79,
                             M82, M90,  M94,  M99)  - Section  8.8 (off-site
                             disposal due to catastrophic events)

                             Some chemicals in addition to metals  and  metal
                             category  compounds   might  not  be  treated  for
                             destruction at a POTW. If you are able to quantify
                             the  amounts  of a toxic chemical  sent to a POTW
                             that  are treated for destruction  and disposed  or
                             released from the POTW untreated, you should
                             divide the amount reported in  Section 6.1 between
                             Sections 8.1c and 8.Id and 8.7  (quantity treated off-
                             site), as appropriate.

                             Sections 8.2 and 8.3.  These relate to an EPCRA
                             Section 313  chemical  or a mixture  containing  an
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                          Instructions for Completing Part II of EPA Form R
EPCRA  Section  313  chemical that is used  for
energy recovery on-site or is sent off-site for energy
recovery, unless it is a commercially available fuel
(e.g.,  fuel oil no.  6). For the purposes of reporting
on Form R, reportable on-site  and off-site energy
recovery is the  combustion  of a  waste stream
containing an EPCRA Section 313 chemical when:

(a)    The  combustion unit is  integrated  into an
      energy  recovery  system   (i.e.,   industrial
      furnaces, industrial kilns, and boilers); and
(b)    The  EPCRA   Section  313  chemical   is
      combustible  and has a  significant  heating
      value (e.g., 5000 BTU)

Note: Metals and metal category compounds cannot
be combusted for energy recovery. For metals and
metal category compounds, you should enter NA in
Sections 8.2 and 8.3.

Section 8.2 is reported in  Section 8 only

Section  8.3  =  Section6.2  (energy  recovery)
SectionS.8  (off-site  energy  recovery  due   to
catastrophic events)

Sections 8.4 and 8.5. These relate to  an EPCRA
Section 313 chemical in a waste that is recycled on-
site or is sent off-site for recycling.

Section 8.4 is reported in  Section 8 only

Section 8.5 =  Section 6.2  (recycling) - Section 8.8
(off-site recycling due to catastrophic events)

Section 8.6 and  8.7. These relate to  an EPCRA
Section 313 chemical (except for most metals and
metal category compounds) or a waste containing an
EPCRA Section 313  chemical that is treated  for
destruction on-site or is sent to a POTW or other
off-site location for treatment for destruction. Most
metal and category compounds are not reported  in
this section because they cannot be destroyed (See
Appendix B).

Section 8.6 is reported in  Section 8 only

Section  8.7  =  Section  6.1   (excluding  most
metal/metal category compounds) + Section 6.2
(treatment) -  Section 8.8  (off-site treatment due
to catastrophic events)
Some chemicals  in addition to metals and metal
category  compounds   might not  be  treated  for
destruction at a POTW. If you  are able to quantify
the amounts of a toxic chemical sent  to a POTW
that  are treated  for destruction  and  disposed  or
released from the  POTW untreated,  you should
divide the amount reported in Section  6.1 between
Sections 8.1c-d and 8.7 (quantity treated off-site), as
appropriate. Facilities  should use their best readily
available  information  to  determine  the  final
disposition of the toxic chemical sent to the POTW.

An EPCRA Section 313  chemical or an EPCRA
Section  313 chemical in a mixture that is a waste
under RCRA  must be reported  in  Sections  8.1
through 8.7.

8.8 Quantity Released to  the  Environment as a
Result of Remedial Actions, Catastrophic Events,
or  One  Time  Events   Not  Associated  with
Production Processes

In Section  8.8,  enter  the  total  quantity of  the
EPCRA Section 313 chemical disposed or released
directly  into the  environment  or  sent off-site  for
recycling, energy recovery, treatment, or disposal
during the reporting year due to  any of the following
events:

    (1)   remedial actions;
    (2)   catastrophic events such as  earthquakes,
         fires, or floods; or
    (3)   one  time  events  not  associated  with
         normal or routine production processes.

These quantities should not be  included in Section
8.1.

The purpose of this section is to separate quantities
recycled,  used for energy recovery, treated,  or
released, including disposals that are associated with
normal  or routine production operations from those
that are  not. While all quantities disposed, released
recycled, combusted for energy recovery, or treated
may ultimately be preventable, this section separates
the quantities that are  more likely to  be reduced or
eliminated by process  oriented  source  reduction
activities  from  those   releases that  are  largely
unpredictable and are less amenable to such source
reduction activities. For example, spills that occur as
a routine part of production operations and could be
reduced  or  eliminated by  improved  handling,
loading, or unloading procedures are included in the
quantities reported  in  Section  8.1 through 8.7  as
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appropriate. A total loss  of containment resulting
from a tank rupture caused by a tornado would be
included in the quantity reported in Section 8.8.

Similarly, the amount of an EPCRA  Section  313
chemical  cleaned  up  from  spills resulting from
normal operations  during  the reporting year would
not be  included  in  Section 8.8. However,  the
quantity  of  the  reported  EPCRA  Section   313
chemical  disposed from  a  remedial action (e.g.,
RCRA  corrective  action)   to   clean  up   the
environmental  contamination resulting from  past
practices should be reported in Section 8.8 because
they  cannot  currently  be  addressed  by  source
reduction  methods. A remedial action for purposes
of Section 8.8 is a waste cleanup  (including  RCRA
and  CERCLA  operations)   within  the  facility
boundary.   Most   remedial   activities   involve
collecting and treating contaminated material.

Also,  releases caused by catastrophic events are to
be incorporated into the quantity reported in Section
8.8.  Such releases  may  be caused by natural
disasters (e.g., hurricanes and earthquakes) or by
large scale accidents (e.g., fires and explosions). In
addition,  releases  due  to   one-time  events  not
associated with production (e.g., terrorist bombing)
are to be included in Section 8.8. These amounts are
generally unanticipated and cannot be addressed by
routine   process  oriented   accident  prevention
techniques.  By  checking  your documentation for
calculating estimates  made  for Part II, Section 5,
"Quantity of  the  Toxic  Chemical Entering Each
Environmental Medium On-site," you may be able
to identify disposal and release  amounts  from the
above   sources.  Emergency  notifications  under
CERCLA and EPCRA as  well as accident histories
required under  the  Clean Air  Act  may provide
useful information. You should also check facility
incident reports and maintenance records to identify
one time or catastrophic events.

Note:  While the information reported in Section 8.8
represents only remedial,  catastrophic, or one  time
events not associated with  production processes,
Section 5 of  Form R (on-site disposal  and other
releases to the environment) and Section 6 (off-site
transfers  for  further  waste  management)  must
include  all on-site disposal  and other releases  and
transfers for disposal as appropriate,  regardless of
whether they  arise from catastrophic, remedial, or
routine process operations.
                             Avoid Double Counting in Sections 8.1 Through
                             8.8
                             Do not  double or  multiple  count quantities  in
                             Sections  8.1 through 8.8. The quantities reported in
                             each of those sections should be mutually exclusive.
                             Do not multiple count quantities entering sequential
                             reportable activities during the reporting year.

                             Quantities  of the  EPCRA  Section  313 chemical
                             disposed or otherwise released into the environment
                             or otherwise managed as waste off-site  due  to
                             remedial  actions;   catastrophic  events such  as
                             earthquakes,  fires,  or floods; or unanticipated one
                             time  events  not associated  with the  production
                             process such as a drunk driver crashing his/her car
                             into a drum storage area. These quantities should be
                             reported  in Section 8.8 only. For example,  10,000
                             pounds of diaminoanisole sulfate is released due to a
                             catastrophic event  and is subsequently treated off-
                             site.  The 10,000 pounds is reported  in Section 8.8
                             but the amount subsequently treated off-site is not
                             reported in Section 8.7.

                             8.9    Production Ratio or Activity Index

                             For  Section  8.9,  you must  provide   a ratio  of
                             reporting year production to prior year production,
                             or provide an "activity index" based on a variable
                             other than production that is the primary influence
                             on the quantity of the reported EPCRA Section 313
                             chemical  recycled,  used  for  energy  recovery,
                             treated, disposed or released.  The ratio or index
                             must be reported to the nearest tenths or hundredths
                             place (i.e., one  or two digits  to the right  of the
                             decimal  point).  For EPCRA  Section  313  PBT
                             chemicals, including the  dioxin  and  dioxin-like
                             compounds category, you will report the same as for
                             chemicals that are not listed as PBT (i.e., up to one
                             or two digits to the right of the decimal point). If the
                             manufacture, processing,  or use  of the reported
                             EPCRA  Section 313  chemical began  during the
                             current reporting year, enter NA as the production
                             ratio  or  activity  index.  Note, this  is  not to  be
                             reported  as a percent (i.e., report  1.10 for a  10
                             percent increase, not  110 percent).

                             It is important to realize that if your  facility reports
                             more  than  one  reported  EPCRA Section  313
                             chemical, the production ratio or activity index may
                             vary  for  different chemicals. For  facilities  that
                             manufacture   reported  EPCRA   Section   313
                             chemicals, the quantities of the EPCRA Section 313
                             chemical(s) produced in the current and prior years
                             provide a good basis for the ratio because that is the
                             primary  business   activity associated  with   the
                             reported  EPCRA Section 313  chemical(s). In most
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                          Instructions for Completing Part II of EPA Form R
cases, the production ratio or activity index must be
based on some variable  of production or activity
rather than  on EPCRA  Section 313  chemical or
material  usage. Indices based on EPCRA Section
313  chemical or material  usage may reflect the
effect of source  reduction activities rather than
changes  in business  activity.  EPCRA Section 313
chemical or material usage is therefore not a basis to
be used  for the production ratio or activity index
where  the  EPCRA Section  313  chemical  is
"otherwise used"  (i.e., non incorporative activities
such as extraction solvents, metal degreasers, etc.).

While several methods are  available to the facility
for determining this data element, the production
ratio or activity index must be based on the variable
that  most directly  affects the  quantities  of the
EPCRA  Section 313 chemical recycled, used  for
energy recovery, treated, disposed or released.

Examples of methods available include:

(1)  Amount of EPCRA  Section 313  chemical
     manufactured in 2009 divided by the amount
     of    EPCRA   Section   313    chemical
     manufactured in 2008; or

(2)  Amount of product produced in 2009 divided
     by  the amount of product produced in 2008.
 Example  20:   Quantity  Released  to  the
 Environment  as  a  Result  of  Remedial
 Actions, Castastrophic Events, or One-Time
 Events  Not  Associated  with  Production
 Processes.

 A chemical manufacturer produces an EPCRA
 Section 313 chemical in a reactor that operates
 at low pressure.  The reactants and the EPCRA
 Section 313 chemical product are piped in and
 out of the  reactor at monitored and controlled
 temperatures. During normal operations, small
 amounts of fugitive emissions occur from the
 valves and flanges in the pipelines.

 Due to  a malfunction in the control  panel
 (which is state-of-the-art and undergoes routine
 inspection  and  maintenance), the temperature
 and pressure in the reactor increase, the reactor
 ruptures, and the EPCRA Section 313 chemical
 is released. Because the malfunction could not
 be  anticipated  and,  therefore,  could not  be
 reasonably  addressed  by   specific  source
reduction  activities,  the amount released is
included in Section 8.8. In this case, much of
the EPCRA Section 313 chemical is released as
a liquid and pools on the ground. It is estimated
that 1,000 pounds of the EPCRA Section  313
chemical  pooled  on  the  ground  and  was
subsequently  collected  and sent off-site  for
treatment.  In  addition, it is  estimated  that
another 200 pounds of the EPCRA Section  313
chemical vaporized directly to the air from the
rupture. The total amount reported in Section
8.8 is  the  1,000 pounds  that pooled on  the
ground  (and subsequently  sent off-site),  plus
the 200 pounds  that vaporized into the air, a
total of 1,200 pounds. The quantity sent off-site
must also  be reported in Section 6 (but not in
Section 8.7) and the  quantity that  vaporized
must be reported as  a fugitive  emission in
Section 5 (but not in Section 8.1b).
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8.10   Did Your Facility Engage in Any Source
       Reduction  Activities  for This Chemical
       During the Reporting Year?

Section 8.10 must  be  completed only if  a source
reduction    activity   was  newly   implemented
specifically  (in whole  or  in part) for the  reported
EPCRA Section 313 chemical during  the reporting
year.  If  your  facility  engaged  in   any  source
reduction  activity for the  reported EPCRA Section
313 chemical  during the reporting year, report the
activity that was implemented  and the method used
to  identify  the   opportunity  for   the   activity
implemented. If your facility did not engage in any
source reduction activity  for the reported EPCRA
Section 313  chemical, enter NA in Section 8.10.1.

Source reduction means any practice that:

•   Reduces  the  amount   of  any  hazardous
    substance, pollutant,  or contaminant  entering
    any waste stream or otherwise released into the
    environment  (including   fugitive  emissions)
    prior to recycling,  energy recovery, treatment,
    or disposal; and

•   Reduces the hazards  to public health  and  the
    environment associated with  the release of such
    substances, pollutants, or contaminants.

The   term  includes  equipment  or  technology
modifications, process  or procedure modifications,
reformulation  or redesign of products, substitution
of   raw    materials,   and   improvements   in
housekeeping, maintenance, training,  or inventory
control.
                             The term "source reduction" does not include any
                             practice that  alters the  physical,  chemical,  or
                             biological   characteristics  or  the   volume  of  a
                             hazardous   substance,  pollutant,  or  contaminant
                             through a  process  or activity that itself is not
                             integral to  and necessary  for the production of a
                             product or the providing of a service.

                             Source reduction activities  do not include recycling,
                             using  for energy recovery, treating, or disposing of
                             an EPCRA  Section  313  chemical.  Report in this
                             section  only   the   source   reduction   activities
                             implemented to reduce or eliminate  the quantities
                             reported in Sections  8.1 through 8.7. The  focus of
                             the section is only those activities that are applied to
                             reduce routine  or reasonably  anticipated  releases
                             and quantities of the reported EPCRA Section 313
                             chemical  recycled,  treated,   used  for   energy
                             recovery, or disposed. Do not report in this section
                             any activities  taken to reduce or  eliminate the
                             quantities reported in Section 8.8. If you have fewer
                             than four source reduction codes in  Section 8.10, an
                             NA should be placed in the first column of the first
                             unused  row to  indicate  the  termination  of the
                             sequence. If all four rows are used, there is no need
                             to terminate the sequence. If there are more than
                             four source  reduction codes, photocopy  Page 5 of
                             Form  R as many  times  as necessary and then
                             number the  boxes consecutively for each source
                             reduction activity. Enter NA when the sequence has
                             terminated, unless the sequence ends at 4, 8, 12, 16,
                             etc. source reduction codes.
 Example 21: Avoiding Double-Counting Quantities in Sections 8.1 through 8.7
 5,000 pounds of an EPCRA Section 313 chemical enters a treatment operation. Three thousand pounds of
 the EPCRA Section 313 chemical exits the treatment operation and then enters a recycling operation. Five
 hundred pounds of the EPCRA Section 313 chemical are in residues from the recycling operation that is
 subsequently sent off-site to a landfill for disposal. These quantities would be  reported as follows in
 Section 8:

 Section 8.1c: 500 pounds disposed
 Section 8.4: 2,500 pounds recycled
 Section 8.6: 2000 pounds treated (5,000 that initially entered - 3,000 that subsequently entered recycling)

 To report that 5,000 pounds were  treated, 3,000 pounds were recycled, and that 500 pounds were sent off-
 site for disposal would result in over-counting the quantities of EPCRA Section 313 chemical recycled,
 treated, and disposed by 3,500 pounds.
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                         Instructions for Completing Part II of EPA Form R
Example 22: Determining a Production Ratio

Your facility's only use of toluene is as a paint carrier for a painting operation. You painted  12,000
refrigerators  in the  current reporting year and  10,000  refrigerators during the preceding  year. The
production ratio for toluene in  this case is 1.2  (12,000/10,000) because  the  number of refrigerators
produced is the primary factor determining the quantity of toluene to be reported in Sections 8.1 through
8.7.

A facility manufactures inorganic pigments, including titanium dioxide. Hydrochloric acid (acid aerosols)
is produced as a waste byproduct during the production process. An appropriate production ratio for
hydrochloric  acid (acid aerosols) is the annual titanium dioxide production,  not the amount of byproduct
generated. If the facility produced 20,000 pounds of titanium dioxide during the reporting year and 26,000
pounds in the preceding year, the production ratio would be 0.77 (20,000/26,000).
                     Toxics Release Inventory Reporting Forms and Instructions                     69

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Example 23: Determining an Activity Index

Your facility manufactures organic dyes in a batch process. Different colors of dyes are manufactured, and
between color changes, all equipment must be thoroughly cleaned with solvent containing glycol ethers to
reduce color carryover. During the preceding year, the facility produced 2,000  pounds of yellow dye in
January,  9,000 pounds  of green  dye  for February through September, 2,000 pounds of red dye  in
November, and another 2,000 pounds of yellow dye in December. This adds up to a total of 15,000 pounds
and four color changeovers. During the reporting year, the facility produced 10,000 pounds of green dye
during the first half of the year and 10,000 pounds of red dye in the second half. If your facility uses glycol
ethers in this  cleaning process  only, an  activity index of 0.5 (based on two color changeovers for the
reporting year divided by four changeovers for the preceding year) is more appropriate than a production
ratio of 1.33 (based on 20,000 pounds of dye produced in the current year divided by 15,000 pounds in the
preceding year). In this case, an activity index, rather than a production ratio, better reflects the factors that
influence the amount of solvent recycled, used for energy recovery, treated, or disposed or released.

A facility that manufactures thermoplastic composite parts for aircraft uses toluene as a wipe  solvent to
clean molds. The solvent is stored in 55-gallon drums and is transferred to 1-gallon dispensers. The molds
are cleaned on an as-needed basis that is not necessarily a function of the parts production rate. Operators
cleaned 5,200 molds during the reporting year,  but only cleaned 2,000 molds  in the previous year. An
activity index of 2.6 (5,200/2,000) represents the activities involving toluene usage in the facility. If the
molds were cleaned after 1,000 parts were manufactured, a production ratio would equal the activity index
and either could be used as the basis for the index.

A facility manufactures  surgical instruments and cleans the metal parts  with 1,1,1-trichloromethane in a
vapor degreaser. The degreasing unit is  operated in a batch mode and the metal parts are cleaned according
to an irregular schedule.  The activity index can be  based upon the total time the metal parts  are in the
degreasing operation. If the degreasing unit operated 3,900 hours during the reporting year and 3,000 hours
the prior year, the activity index is 1.3 (3,900/3,000).	
Example 24: "NA" is Entered as the Production Ratio or Activity Index

Your facility began production of semiconductor chips during this reporting year. Perchloroethylene is used
as a cleaning solvent for this operation and this is the only use of the EPCRA Section 313 chemical in your
facility. You would enter NA in Section 8.9 because you have no basis of comparison in the prior year for
the purposes of developing the activity index.	
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                         Instructions for Completing Part II of EPA Form R
Example 25: Determining the Production Ratio Based on a Weighted Average

At many facilities, a reported EPCRA Section 313 chemical is used in more than one production process. In
these cases, a production ratio or activity index can be estimated by weighting the production ratio for each
process based on the respective contribution of each process to the quantity of the reported EPCRA Section
313 chemical recycled, used for energy recovery, treated, or disposed.

Your facility paints bicycles with paint containing toluene. Sixteen thousand bicycles were produced in the
reporting year and 14,500 were produced in the prior year. There were no significant design modifications
that  changed the total  surface area to  be painted for each bike.  The  bicycle production ratio  is 1.1
(16,000/14,500). You estimate  12,500 pounds of toluene  recycled, used for energy recovery, treated,
disposed or released as a result of bicycle production. Your facility also uses toluene as a solvent in  a glue
that  is used  to make components and add-on equipment for the bicycles. Thirteen thousand components
were manufactured in the reporting year as compared to  15,000 during the prior year. The production ratio
for the components using toluene is 0.87 (13,000/15,000). You estimate 1,000 pounds of toluene treated,
recycled, used for energy recovery, disposed or released as a result of components production. A production
ratio can be  calculated by  weighting each of the production ratios based on the relative contribution each
has to the quantities of toluene treated, recycled, used for energy recovery, disposed or released during the
reporting year (13,500 pounds). The production ratio is calculated as follows:

Production ratio = 1.1  x (12,500/13,500) + 0.87 x (1,000/13,500) = 1.08	
                     Toxics Release Inventory Reporting Forms and Instructions                     71

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Example 26: Source Reduction

A facility assembles and paints furniture. Both the glue used to assemble the furniture and the paints contain
EPCRA Section 313 chemicals. By examining the gluing process, the facility discovered that a new drum of
glue is opened at the beginning of each shift, whether the old drum is empty or not. By adding a mechanism
that prevents the drum from being changed before it is empty, the need for disposal of the glue is eliminated
at the source. As a result, this activity is considered source reduction. The painting process at this facility
generates a solvent waste that contains an EPCRA Section 313 chemical that is collected and recovered.
The  recovered solvent is used to clean the painting equipment. The recycling activity does not reduce the
amount of EPCRA Section 313 chemical recycled, and therefore  is not considered a  source reduction
activity.
Source Reduction Activities
You must enter in the first column of Section 8.10,
"Source  Reduction  Activities," the  appropriate
code(s)  indicating the type of actions taken to
reduce the amount of the reported EPCRA Section
313  chemical  disposed  or otherwise released  (as
reported in Section 8.1), used for energy recovery
(as reported  in Sections 8.2-8.3),  recycled  (as
reported   in  Sections  8.4-8.5),  or  treated  (as
reported  in Sections 8.6-8.7).  The list of codes
below includes many, but not all, of the codes
provided in the RCRA biennial report. Remember
that  source reduction activities include only those
actions or techniques that reduce or eliminate  the
amounts  of the  EPCRA Section 313  chemical
reported in Sections 8.1 through 8.7. Actions taken
to recycle, combust for energy recovery, treat, or
dispose  of the EPCRA  Section 313  chemical  are
not considered source reduction activities.

Source Reduction Activity Codes:

Good Operating Practices
W13   Improved maintenance scheduling, record
       keeping, or procedures
W14   Changed production schedule to minimize
       equipment and feedstock changeovers
W19   Other changes made in operating practices

Inventory Control
W21   Instituted procedures to ensure that
       materials do not stay  in inventory beyond
       shelf-life
W22   Began to test outdated material — continue
       to use if still effective
W23   Eliminated shelf-life requirements for
       stable materials
W24   Instituted better labeling procedures
W25   Instituted clearinghouse to exchange
       materials that would otherwise be
       discarded
W29   Other changes made in inventory control
                              Spill and Leak Prevention
                              W31   Improved storage or stacking procedures
                              W32   Improved procedures for loading,
                                     unloading, and transfer operations
                              W33   Installed overflow alarms or automatic
                                     shut-off valves
                              W35   Installed vapor recovery systems
                              W36   Implemented inspection or monitoring
                                     program of potential spill or leak sources
                              W39   Other changes made in spill and leak
                                     prevention

                              Raw Material Modifications
                              W41   Increased purity of raw materials
                              W42   Substituted raw materials
                              W49   Other raw material modifications made

                              Process Modifications
                              W51   Instituted re-circulation within a process
                              W52   Modified equipment, layout, or piping
                              W53   Used a different process catalyst
                              W54   Instituted better controls on operating bulk
                                     containers to minimize discarding of empty
                                     containers
                              W55   Changed from small volume containers to
                                     bulk containers to minimize discarding of
                                     empty containers
                              W5 8   Other process modifications made

                              Cleaning and Decreasing
                              W59   Modified stripping/cleaning equipment
                              W60   Changed to mechanical stripping/cleaning
                                     devices (from solvents or other materials)
                              W61   Changed to aqueous cleaners (from
                                     solvents or other materials)
                              W63   Modified containment procedures for
                                     cleaning units
                              W64   Improved draining procedures
                              W65   Redesigned parts racks to reduce drag out
                              W66   Modified or installed rinse systems
                              W67   Improved rinse equipment design
                              W68   Improved rinse equipment operation
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                          Instructions for Completing Part II of EPA Form R
W71   Other cleaning and decreasing
       modifications made

Surface Preparation and Finishing
W72   Modified spray systems or equipment
W73   Substituted coating materials used
W74   Improved application techniques
W75   Changed from spray to other system
W78   Other surface preparation and finishing
       modifications made

Product Modifications
W81   Changed product specifications
W82   Modified design or composition of product
W83   Modified packaging
W89   Other product modifications made

Methods to Identify Activity
In columns a  through c  of Section  8.10, the
"Methods to Identify Activity," you must enter one
or more of the following code(s) that correspond to
those   internal   and   external  method(s)  or
information sources you used to  identify the
possibility   for   a  source  reduction   activity
implementation at your facility.  If more than three
methods were used to identify the source reduction
activity, enter only the three codes that contributed
most to the decision to implement the activity.

T01    Internal  pollution  prevention  opportunity
       audit(s)
T02    External pollution prevention  opportunity
       audit(s)
T03    Materials balance audits
T04    Participative team management
T05    Employee  recommendation (independent
       of a formal company program
T06    Employee   recommendation   (under   a
       formal company program
T07    State  government  technical  assistance
       program
T08    Federal  government  technical  assistance
       program
T09    Trade    association/industry    technical
       assistance program
T10    Vendor assistance
Til    Other

8.11    Is Additional Optional Information on
       Source Reduction, Recycling, or
       Pollution Control Activities Included
       with this Report?
Check "Yes" for this data element if you wish to
submit  any  additional  optional  information  on
source reduction, recycling, or pollution  control
activities you have  implemented in the reporting
year or in prior years  for the reported EPCRA
Section 313 chemical. If you are using TRI-MEweb
to submit your  report, you  can use the pull-down
text box feature to describe your source reduction,
recycling, or  pollution control activities. You may
submit such additional information in hard-copy in
addition to, or instead of, the information supplied
in the TRI-MEweb text box feature. If you wish to
submit by  regular mail, please use  the  following
address:

       TRI Reporting Center
       P.O. Box 10163
       Fairfax, VA 2203 8

To submit hard-copy information for Section 8.11
by certified or  overnight mail, use  the  following
address:

       CGI Federal, Inc.
       c/o EPA Reporting Center
        12601 Fair Lakes Circle
       Fairfax, VA 22033

All  information  submitted in  hard-copy  must
include the name, address, and TRIFID number for
the facility submitting the information.

If there is a contact person at the facility, other than
the technical  or public contact provided in Part I,
Section 4, the summary page  should include that
person's   name  and   telephone   number  for
individuals who wish to  obtain further information
about those activities. Also submit a copy of this
additional  information  to  the appropriate  state
agency as  part of the  Form  R submittal  to  that
agency.
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D. Instructions for Completing
Form R Schedule 1 (Dioxin and
Dioxin-like Compounds)

D. 1  What is the Form R Schedule 1 ?
The Form R Schedule 1 is a four-page form that
mirrors the data elements from Form R Part II
Chemical-Specific Information sections 5, 6, and
8 (current year only). The Form R Schedule 1
requires the reporting of the individual grams
data for each member of the dioxin and dioxin -
like compounds category present, and is
submitted as an adjunct to the Form R.
Beginning with reporting year 2008, facilities
that file Form  R reports for the dioxin and
dioxin-like compounds category are required to
determine if they have any of the information
required by the new Form R Schedule 1.
Facilities that have any of the information
required by Form R Schedule 1 must submit a
Form R Schedule 1 in addition to the Form R.
D.2  Who is required to file a Form R
       Schedule 1?

Only facilities that file reports for the dioxin and
dioxin-like compounds category may be required
to file a Form R Schedule 1. Facilities that have
any of the data required by Form R Schedule 1
for the individual members of the dioxin and
dioxin-like compounds category must submit a
Form R Schedule 1, in addition to the Form R.
EPA notes that dioxin and dioxin-like
compounds are not measured as a total quantity;
the measurements are based on the individual
compounds within the category. Emission factors
for dioxin and dioxin-like compounds are also
based on emission factors for the individual
compounds within the category.  EPA's guidance
document for dioxin and dioxin-like compounds
(Emergency Planning And Community Right-
To-Know Act - Section 313: Guidance for
                             Reporting Toxic Chemicals within the Dioxin and
                             Dioxin-like Compounds Category, EPA-745-B-
                             00-021, December 2000) includes tables that
                             contain the emission factors for the individual
                             members of the dioxin and dioxin-like compounds
                             category. Since measured data and emission
                             factor data are based upon data for the individual
                             members of the dioxin and dioxin-like compounds
                             category, the information required by Form R
                             Schedule 1 should be available to facilities that
                             file Form R reports for the dioxin and dioxin-like
                             compounds category.
                             D.3  What information is reported on
                                    the Form R Schedule 1 ?


                             The only data reported on the Form R Schedule 1
                             is the mass quantity information required in
                             sections 5, 6, and 8 (current year only) of the
                             Form R. All of the other information required in
                             sections 5, 6, and 8 of the Form R (off-site
                             location names, stream or water body names, etc.)
                             would be the same so this information is not
                             duplicated on Form R Schedule 1. For example,
                             if a facility reported 5.3306 grams on Form R
                             Section 5.1 for fugitive or non-point air emissions
                             for the dioxin and dioxin-like compounds
                             category then the facility would report on the
                             Form R Schedule 1 the grams data for each
                             individual member of the category that
                             contributed to the 5.3306 gram total. The sum of
                             the gram quantities reported for each individual
                             member of the category should equal the total
                             gram quantity reported for the category on Form
                             R for each data element (see examples below).
                             The NA box has the same meaning on Form R
                             Schedule 1 as it does on the Form R and should
                             only be marked if it is marked on the Form R.
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                         Instructions for Completing Part II of EPA Form R
Form R Section 5 Example
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE

5.1
Fugitive or non-point
air emissions
N
A

A. Total Release (pounds/year*)
(Enter a range code** or
estimate)
5.3306
B. Basis of
Estimate
(enter code)
M
C. % From
Stormwater

Form R Schedule 1 Section 5 Example
SECTION 5. QUANTITY OF DIOXIN AND DIOXIN-LIKE COMPOUNDS ENTERING EACH ENVIRONMENTAL MEDIUM
ONSITE

t~
1
o
•3
_g
T3
1
1
5
fl
£
Efl
3
2
p
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
5.1 NA
Fugitive or non-
point air emissions
0.0035
0.0059
0.0071
0.0008
0.0065
0.0923
0.5720
0.0723
0.0695
0.0399
0.3562
0.1309
0.0132
0.0815
1.4625
0.3126
2.1039
N
A
Stack or point
air emissions

















Discharges to receiving streams or water bodies
(enter data for one stream or water body per box)
5.3.1

















5.3.2

















5.3.3

















The Form R Schedule 1 provides boxes for recording the gram quantities for all 17 individual members of
the dioxin and dioxin-like compounds category.  The boxes on the Form R Schedule 1 for each release type
are divided into 17 boxes. Each of the boxes (1-17) correspond to the individual members of the dioxin
category as presented in Table I.
                                             Table I
Box #    CAS#           Chemical Name
1        01746-01-6     2,3,7,8-Tetrachlorodibenzo-p-dioxin
2        40321-76-4     1,2,3,7,8-Pentachlorodibenzo- p-dioxin
3        39227-28-6     1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin
4        57653-85-7     1,2,3,6,7,8-Hexachlorodibenzo- p-dioxin
5        19408-74-3     1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin
6        35822-46-9     1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
7        03268-87-9     1,2,3,4,6,7,8,9-Octachlorodibenzo- p-dioxin
8        51207-31-9     2,3,7,8-Tetrachlorodibenzofuran
9        57117-41-6     1,2,3,7,8-Pentachlorodibenzofuran
Abbreviation
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
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10       57117-31-4      2,3,4,7,8-Pentachlorodibenzofuran                 2,3,4,7,8-PeCDF
11       70648-26-9      1,2,3,4,7,8-Hexachlorodibenzofuran               1,2,3,4,7,8-HxCDF
12       57117-44-9      1,2,3,6,7,8-Hexachlorodibenzofuran               1,2,3,6,7,8-HxCDF
13       72918-21-9      1,2,3,7,8,9-Hexachlorodibenzofuran               1,2,3,7,8,9-HxCDF
14       60851-34-5      2,3,4,6,7,8-Hexachlorodibenzofuran               2,3,4,6,7,8-HxCDF
15       67562-39-4      1,2,3,4,6,7,8-Heptachlorodibenzofuran             1,2,3,4,6,7,8-HpCDF
16       55673-89-7      1,2,3,4,7,8,9-Heptachlorodibenzofuran             1,2,3,4,7,8,9-HpCDF
17       39001-02-0      1,2,3,4,6,7,8,9-Octachlorodibenzofuran            1,2,3,4,6,7,8,9-OCDF

It is extremely important that facilities enter their grams data for the individual members of the category
based on the box numbers in Table I (do not use the listing order from the 2007 or earlier versions of the
reporting instructions).  This information will be used to calculate toxic equivalency values using toxic
equivalency factors that are specific to each member of the category. As with reporting on the Form R,
facilities should report on the Form R Schedule 1 to the level of accuracy that their data supports, up to
seven digits to the right of the decimal. EPA's reporting software and data management systems support
data precision to seven digits to the right of the decimal.  EPA strongly encourages facilities that report for
the dioxin and dioxin-like compounds category to file their reports electronically to reduce the potential for
errors when transferring the individual grams data from hard copy reports.
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                      Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
E.    Facility Eligibility
       Determination for Alternate

       Threshold and for
       Reporting on EPA Form A
This section will help to determine whether you
can submit the simplified Form A Certification
Statement (hereafter referred to as Form A). The
criteria are based on the total annual reportable
amount of the listed chemical or chemical category
and the amount manufactured, processed, or
otherwise used. Note that, effective in Reporting
Year 2008, the TRI Burden Reduction Rule has
been voided by Congress. The criterion for using
Form A has returned to what they were prior to
Reporting Year 2006. The criteria are explained
below. For more information about the final rule,
see the TRI homepage at http://www.epa.gov/tri/.

E.I   Alternate Threshold

On November 30,  1994, EPA published a final rule
(59 FR 61488) that provides qualifying facilities an
alternate threshold of 1 million pounds. Eligible
facilities wishing to take advantage of this option
may certify on a simplified two-page form referred
to as Form A Certification Statement and do not
have to use Form R. The "TRI Alternate Threshold
for Facilities with Low Annual Reportable
Amounts," provides facilities  otherwise meeting
EPCRA section  313 reporting thresholds the option
of certifying on Form A provided that they do not
exceed 500 pounds for the total annual reportable
amount (defined below) for that chemical, and that
their amounts manufactured or processed or
otherwise used do not exceed one-million pounds.
As with determining section 313  reporting
thresholds, amounts manufactured, processed, or
otherwise used are to be considered independently.
This modification does not apply to forms being
submitted on or before July 1, 1995 (covering the
1994 reporting year). If you fill out a Form A for
an EPCRA section 313 chemical, do not fill out a
Form R for that same chemical.

However, there is an exception to the alternate
threshold rule described in the preceding
paragraph. All PBT chemicals (except certain
instances of reporting lead in stainless steel, brass
or bronze alloys) are excluded from eligibility for
the alternate threshold.

E.2    What is the Form A Certification
       Statement?

The   Form   A,   which  is  described   as   the
"certification  statement"  in  59  FR  61488,  is
intended as a means to  reduce the compliance
burden associated with EPCRA section 313.  If a
facility chooses to use Form A as a substitute for
Form R for  any eligible chemical, it  must be
submitted on  an annual basis. Facilities wishing to
take  advantage of this burden reducing option may
only submit Form A for  chemicals that  meet the
conditions  described  in  section  E.I,  Alternate
Threshold, and should not submit a Form R to the
TRI   Data  Processing   Center  for  the  same
chemicals. The information submitted on the Form
A includes facility identification information and
the chemical  or  chemical category  identity.  The
information submitted on  the Form A will appear
in the TRI data  base  in the  same manner that
information  submitted  on Form R appears.  An
approved  Form  A   has  been  included  in  this
Reporting Forms and Instructions document.

 E.3   What Is the Annual Reportable
       Amount (ARA)?

For  the  purpose  of this  optional   reporting
modification,  the annual reportable amount (ARA)
is equal to the combined total quantities released at
the facility (including disposed within the facility),
treated at the facility (as represented by amounts
destroyed or converted by  treatment processes),
recovered at the facility as a result of recycling
operations, combusted for  the purpose of energy
recovery at the facility, and amounts transferred
from the facility to off-site locations for the
purpose of recycling, energy recovery, treatment,
and/or disposal. These quantities correspond to the
sum  of amounts reportable for data elements on
EPA Form R (EPA Form 9350-1; Rev. 10/09) as
Part  II column B of section 8, data elements 8.1
(quantity released), 8.2 (quantity used for energy
recovery on-site), 8.3  (quantity used for energy
recovery off-site), 8.4 (quantity recycled onsite),
8.5 (quantity recycled off-site), 8.6 (quantity
treated on-site), and 8.7 (quantity treated off-site).
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E.4   Recordkeeping

Each owner or operator who determines that they
are eligible, and wishes to apply the alternate
threshold to a particular chemical, must retain
records substantiating this determination for a
period of three years from the date of the
submission of the Form A. These records must
include sufficient documentation to  support
calculations as well as the calculations made by the
facility that confirm their eligibility  for each
chemical for which the alternate threshold was
applied.

A facility that fits within the category description,
and manufactures, processes or otherwise uses no
more than one million pounds of an  EPCRA
Section 313 chemical annually, and  whose
owner/operator elects to take advantage of the
alternate threshold, is not considered an EPCRA
Section 313 covered facility for that chemical for
the purpose of submitting a Form R. This
determination may provide further regulatory relief
from other federal or state regulations that apply to
facilities on the basis of their EPCRA Section 313
reporting status. A facility will need to reference
other applicable regulations to determine if their
actual  requirements may be  affected  by  this
reporting modification.

E.5   Multi-establishment Facilities

For the purposes of using Form A, the facility must
also make  its determination based  upon the entire
facility's   operations   including   all    of  its
establishments  (see  59  FR   61488  for  greater
detail). If the  facility as a whole  is able  to take
advantage of the alternate threshold, a single  Form
A is required. The eligibility to submit a Form A
must be made on  a whole facility determination.
Thus, all of the information necessary to make the
determination  must be  assembled  to  the  facility
level.

E. 6   Trade Secrets

When  making a trade  secret  claim on a Form A
submission, EPA is requiring that a facility submit
a unique Form A for  each EPCRA Section 313
chemical meeting the  conditions of the alternate
threshold.  Facilities  may  assert a trade  secrecy
claim for a chemical identity on the Form A  as on
the Form R. Reports submitted on  a per chemical
basis protect against the disclosure of trade secrets.
                             Form As with trade secrecy claims, like Form Rs
                             with  similar claims, will  be separately  handled
                             upon  receipt   to   protect  against   disclosure.
                             Commingling trade secret chemical identities with
                             non trade secret chemical  identities on the same
                             submission increases the risk of disclosure.
                                   Do not submit trade secret reports
                                             electronically.
                             E. 7   Metals and Metal Category
                                     Compounds
                             For metal category compounds, the amount applied
                             toward the  ARA is the amount of parent  metal
                             waste  that  is  reported  on  Form R,  but  the
                             thresholds apply to the amount of metal category
                             compounds  manufactured, processed, or otherwise
                             used.  For Form A certification  involving  both
                             listed   parent   metals  and   associated   metal
                             compounds,  the  one  million  pound  alternate
                             threshold must be applied separately to the  listed
                             parent   metal   and   the   associated    metal
                             compound(s).  Threshold determinations  must be
                             made  independently  for  each because they are
                             separately listed EPCRA Section 313 chemicals.

                             •   If the threshold is exceeded for the listed parent
                                 metal but not the  associated  metal  category
                                 compounds, then the releases of metal reported
                                 on  Form  R for  the  parent  metal need not
                                 include  the  releases from the metal  category
                                 compounds.

                             •   If both  the parent metal and  the associated
                                 metal   compounds   exceed   the   alternate
                                 threshold, then the facility has the option of
                                 filing one Form R for both, using the  metal
                                 category compound name and  reporting total
                                 releases based on parent metal content.

                             •   If neither the parent metal nor the associated
                                 metal   compounds   exceed   the   alternate
                                 threshold, then the facility must use a separate
                                 listing on Form A for each, since the reporting
                                 thresholds must be applied to each listed parent
                                 metal and all  compounds in the associated
                                 compound   category.   EPA  believes   it  is
                                 appropriate  to make the  distinction between
                                 filing the Form R and  Form A because the
                                 Form R accounts for amounts of metal released
                                 or otherwise managed and Form A verifies that
                                 the alternate threshold for each listed chemical
                                 or chemical category has not been exceeded.
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                       Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
Similarly, separate listings  on Form A must  be
submitted for all  other listed  chemicals  even if
EPA allows one listing on Form R to be filed for
two or  more listed chemicals  (e.g., o-xylene,  p-
xylene and xylene (mixed isomers)). For example,
if a facility  processes in three separate  process
streams, xylene (mixed isomers), o-xylene, and p-
xylene,  and exceeds the conditions of the alternate
threshold for each of these  listed  substances, the
facility  may combine the  appropriate information
on  the  o-xylene,  p-xylene, and  xylene   (mixed
isomers) into one Form R, but cannot combine the
reports into one listing on Form A.

Facilities  that  process o-xylene,   p-xylene, and
xylene (mixed isomers) in  separate process streams
and do  not exceed the conditions of the alternate
threshold for one or more of the compounds may
submit a separate Form A  for each of the forms of
xylene meeting the alternate threshold and report
on Form R for those forms that do  not.  Similar to
reporting on the parent metals and their  associated
category compounds  described above,  facilities
that separately process all types (i.e., isomers) of
xylene  with individual activity levels within the
conditions of the alternate threshold should file a
separate Form A for each type of xylene.

Beginning with the 1998  reporting  year, facilities
may enter as many chemicals as are eligible on a
single Form A.
                      Toxics Release Inventory Reporting Forms and Instructions                     79

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F.     Instructions for Completing
       EPA Form A
For all parts of Form A:

•   You  should type or print information  on the
    form in the format requested and use black ink.
    (Using blue ink for the certification signature is
    suggested  as  a  means  of  indicating  its
    originality.)
•   All information on the Form A is required.

•   Do not leave items  in Parts I  and II  on the
    Form A blank unless specifically directed to do
    so; if an item does not apply to you, you should
    enter  NA in  the  space provided. If  your
    information  does  not  fill  all  the  spaces
    provided for a type of information,  enter NA,
    in the next blank space in the sequence.
•   Do  not  submit  an  incomplete  form.  The
    certification  statement  (Part I,  Section 3)
    specifies  that the  report   is  complete as
    submitted. See Page  1  of these instructions for
    the definition of a complete submission.

Part L    Facility Identification
          Information

Section 1.   Reporting Year
This is  the calendar year to which the reported
information applies, not the year  in  which you are
submitting the report. Information for the reporting
year 2009 must be submitted on  or before  July 1,
2010.

Section 2.   Trade Secret Information
2.1    Are you claiming the EPCRA Section 313
      chemical identified on Page 3 a trade
      secret?
If facilities wish to report more than  one eligible
chemical on the  same Form A, then they are not
able to  make trade  secrecy claims.  Any trade
secrecy claims should be made on a separate form,
and then the process is the same as using the Form
R and as described in the following instructions.
The  specific identity of the EPCRA  Section 313
chemical being reported in Part II, Section  1, may
be designated as a trade secret. If you are making a
trade secret claim,  mark  "yes"  and proceed to
Section 2.2. Only check "yes" if you manufacture,
process, or otherwise use the EPCRA Section 313
chemical whose identity is a trade secret. (See Page
                             3 of these instructions for specific information on
                             trade secrecy claims.) If you checked "no," proceed
                             to Section 3; do not answer Section 2.2.
                                 Do not submit trade secret reports
                             electronically. See last year's Reporting
                                      Forms and Instructions.
                             2.2    If "yes" in 2.1, is this copy sanitized or
                                   unsanitized?
                             You should check "sanitized" if this  copy of the
                             report is the public version that does not contain
                             the EPCRA Section 313 chemical identity but does
                             contain  a  generic  name  that  is  structurally
                             descriptive in its place, and you have claimed the
                             EPCRA Section 313 chemical identity trade secret
                             in  Part  I,   Section   2.1.  Otherwise,  check
                             "unsanitized."

                             Section 3.    Certification

                             The Form A  must be signed  by a senior official
                             with management  responsibility for the person (or
                             persons)   completing   the   form.  A   senior
                             management official must certify the accuracy and
                             completeness  of the  information reported on the
                             form by signing  and dating  the  Form  A.  Each
                             report must contain an original  signature. Unlike
                             the  certification statement contained on  Form R,
                             the   certification   statement  provided  on  the
                             Alternate  Threshold  Form  A  pertains  to the
                             facility's eligibility of having met the conditions as
                             described in 40 CFR Section  372.27.  You should
                             print or type in the space provided the name and
                             title of the  person who  signs the  statement. This
                             certification   statement  applies   to   all  the
                             information supplied on the form and should be
                             signed  only  after  the form has been completed.
                             Failure to certify submissions will lead to a Notice
                             of Non-Compliance.  Please see Appendix C.2
                             Levels of Errors Identified in FDPs.

                             Section 4.    Facility Identification

                             4.1    Facility Name, Location, and TRI
                                   Facility Identification Number

                             Enter the full  name that the facility presents to the
                             public and its customers in doing business (e.g., the
                             name that appears on invoices, signs, and  other
                             official  business   documents).  Do  not use  a
                             nickname for the facility (e.g., Main Street Plant)
                             unless that is  the legal name of the facility under
                             which  it does  business.  Also  enter the  street
                             address, mailing address, city, county, state, and
                             zip code in the space provided. Do not use a post
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                       Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
office box number as the street address. The street
address provided must be the location where  the
EPCRA Section 313 chemicals are manufactured,
processed,  or  otherwise  used.  If  your mailing
address and street address are the same, you  should
enter NA in the space for the mailing address.

If your facility is not in a county, put the name of
your   city,  district   (for  example   District   of
Columbia), or parish  (if you are  in Louisiana) in
the county block of the Form R and Form A as well
as in the County field of TRI-MEweb . "NA" or
"None" are not acceptable entries.

If you have submitted a Form A or Form  R for
previous  reporting   years,  a   TRI  Facility
Identification Number has been  assigned to your
facility.  If   you  know   your  TRI  Facility
Identification Number, complete  Section 4.  If you
do  not know your  TRI  Facility  Identification
Number, contact the CDX Help Desk toll free at 1-
888-890-1995.  If your facility has moved,  do  not
enter your TRI facility identification number, you
should enter "New Facility."

The   TRI   Facility   Identification   Number   is
established by the first Form R submitted by a
facility at a  particular location. This identification
number is retained  by the  facility even  if  the
facility changes  name,  ownership,  production
processes,  SIC  or   NAICS  codes,  etc.  This
identification number will stay with this location. If
a new  facility  moves to this location it should  use
this    TRI    Facility   Identification   Number.
Establishments of a facility that report separately
should use the TRI Facility Identification Number
of the facility.

You should  enter "New Facility" in the space for
the TRI  Facility Identification number if  this is
your first submission.

4.2    Federal Facility Designation
Executive Order 13423 directs federal facilities to
comply with Right-To-Know Laws  and Pollution
Prevention Requirements.  Please indicate in 4.2A.
if the  reporting facility is a federal facility or in
4.2.B if the  submitter is a contractor at a federal
facility (GOCO). If the reporting facility is not a
federal facility, you should leave this space blank.
Form  R  allows  a  facility to  report  multiple
submissions  for the same chemical if the facility is
composed of several distinct establishments. This
data element provides the option of reporting full
or partial facility information on Form R, however,
this  is not  applicable  for those facilities  taking
advantage of the Alternate Threshold and Form A.

4.3    Technical Contact
Enter the  name and telephone number (including
area code) of a technical representative whom EPA
or state officials may contact for clarification of the
information  reported on Form A. You should also
enter an  email address  for this  person. EPA
encourages facilities to  provide  an  email address
for its Technical Contact on their TRI submissions
because they will  be  able to  receive  important
program updates and email alerts notifying them
when their FDP has been updated and is  available
on the FDP  website. If the technical contact does
not have an email  address you  should enter NA.
This contact person does not have to be the same
person who prepares the report or signs the Form A
and does not necessarily need to be someone at the
location of  the reporting facility. However, this
person should be familiar with the details  of the
report so that he or she can answer questions about
the information provided.

4.4    Public Contact
Enter the  name and telephone number (including
area code)  of a  person  who  can  respond  to
questions  from the public  about the form. You
should also enter an e-mail address for this person.
If you choose to designate the same  person as both
the Technical and the Public Contact, or you do not
have a Public Contact,  you may enter "Same  as
Section 4.3" in this space. This contact person does
not have to  be the  same person  who prepares the
form or signs the Certification Statement  and does
not necessarily need to be someone  at the location
of the reporting facility.

4.5    North American Industry Classification
       System (NAICS) Code
Enter the appropriate  six digit North American
Industry Classification System (NAICS) Code that
is the  primary NAICS  Code for your facility  in
Section 4.5(a).  (Use 2007 NAICS  codes.) Enter
any other applicable NAICS for your facility in 4.5
(b)-(f). The  tables in Section B list the required
NAICS codes and their exceptions/ limitations.  If
you  do not  know your  NAICS  code, consult the
2007 NAICS Manual  (see  Section B.2  of these
                      Toxics Release Inventory Reporting Forms and Instructions
                                            81

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instructions for ordering information) or check the
SIC   to    NAICS    crosswalk   tables    at
http://www.census.gov.

The  North  American  Industry   Classification
System (NAICS) is the economic classification
system that replaces the 1987 SIC code system. A
Federal Register notice was  published on June 6,
2006 (71 FR 32464). NAICS codes are required on
TRI reporting forms beginning with RY 2006. A
subsequent Federal Register  notice was published
on June 9, 2008 (73 FR 32466) to incorporate 2007
OMB revisions and other corrections to the NAICS
codes used for TRI Reporting.

4.6    Dun & Bradstreet Number(s)
Enter the nine digit number assigned by D&B for
your facility or each establishment within your
facility. These numbers code the facility for
financial purposes. This number may be available
from your facility's treasurer or financial officer.
You can also obtain the numbers by calling 1-888-
814-1435 or visiting this web site:
https://www.dnb.com/product/dlw/form cc4.htm.
If a facility does not subscribe to the D&B service,
a number can be obtained, toll free at
1-800-234-3867 (8:00 AM to 6:00 PM, Local
Time) or on the Web at http://www.dnb.com. If
none of your establishments has been assigned a
D&B number, you should enter NA in box (a). If
only some of your establishments  have been
assigned Dun & Bradstreet numbers, enter those
numbers in Part I, Section 4.6.
                                     (meaning that none of the facility owners directly
                                     owns at least 50 percent of the voting stock of the
                                     facility at issue), the facility should provide the
                                     name of the parent company of either the facility
                                     operator or the owner with the largest ownership
                                     interest in the facility. If neither the operator nor
                                     this owner has a parent company, then the NA box
                                     should be checked.

                                     5.1    Name of Parent Company
                                     Enter the name of the corporation or other business
                                     entity that is your ultimate US parent company. If
                                     your facility has no parent company, you should
                                     check the NA box.

                                     5.2    Parent Company's Dun & Bradstreet
                                           Number
                                     Enter the D&B number for your ultimate US parent
                                     company, if applicable. The number may be
                                     obtained from the treasurer or financial officer of
                                     the company or you may call 1-888-814-1435 or
                                     visit this web site:
                                     https://www.dnb.com/product/dlw/form  cc4 .htm.
                                     If your parent company does not have a D&B
                                     number, you should check the NA box.
Section 5.
Parent Company
Information
You must provide information on  your parent
company. For purposes of the Form A, a parent
company is defined as the highest level company,
located in the United States, that directly owns at
least  50  percent  of  the  voting  stock of  your
company. If  your  facility  is owned by a foreign
entity,  you  should enter  NA  in  this  space.
Corporate names  should  be  treated  as  parent
company  names  for  companies  with multiple
facility   sites.   For  example,   the  Bestchem
Corporation is not owned or controlled by  any
other corporation  but  has  sites  throughout the
country whose names begin with Bestchem. In this
case, Bestchem Corporation should be listed as the
parent company. Note that a facility that is a 50:50
joint venture  is its own parent company. When a
facility is owned by more than one company and
there is no parent  company  for the entire facility
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                     Facility Eligibility Determination for Alternate Threshold
                     and for Reporting on EPA Form A Certification Statement
Part II.   Chemical Identification

Reporting  on the Alternate  Threshold  Form A
Certification Statement for metals, metal category
compounds, and mixed  isomers differs  somewhat
from Form R reporting. Please refer to Section E.7
for these guidelines.

Section 1.    Toxic Chemical Identity

(Important:  DO NOT complete this section if you
completed Section 2 of Part II below.)

1.1   CAS Number
Enter the  Chemical Abstracts  Service  (CAS)
registry number in Section 1.1 exactly as it appears
in Table II  of these  instructions for the  chemical
being reported. CAS  numbers are cross-referenced
with an alphabetical list of  chemical  names in
Table II. If you are  reporting one of the EPCRA
Section  313  chemical categories (e.g., chromium
compounds),  you should  enter  the  applicable
category code in the CAS number space. EPCRA
Section  313 chemical category codes  are  listed
below and  can also be  found  in Table He and
Appendix B.I.

EPCRA Section 313 Chemical Category Codes:

NO 10  Antimony compounds
N020  Arsenic compounds
N040  Barium compounds
N050  Beryllium compounds
N078  Cadmium compounds
N084  Chlorophenols
N090  Chromium compounds
N096  Cobalt compounds
N100  Copper compounds
N106  Cyanide compounds
N120  Diisocyanates
N150  Dioxin and dioxin-like compounds*
N171  Ethylenebisdithiocarbamic  acid,  salts and
       esters (EBDCs)
N230  Certain glycol ethers
N420  Lead compounds
N450  Manganese compounds
N458  Mercury compounds
N495  Nickel compounds
N503  Nicotine and salts
N511  Nitrate compounds  (water  dissociable;
       reportable only when in aqueous solution)
N575  Polybrominated biphenyls (PBBs)
N583  Polychlorinated alkanes (CIO to C13)
N590  Poly cyclic aromatic compounds (PACs)
N725  Selenium compounds
N740  Silver compounds
N746  Strychnine and salts
N760  Thallium compounds
N770  Vanadium compounds
N874  Warfarin and salts
N982  Zinc compounds

* Facilities cannot take the alternate threshold for
chemicals  and chemical categories listed as PBT
chemicals.

If you are making a trade secret claim, you must
report the  specific EPCRA Section 313  chemical
identity   on  your  unsanitized  Form  A  and
unsanitized substantiation form.  Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include  a generic  name  that  is  structurally
descriptive in  Part II, Section 1.3 of your sanitized
Form A.

1.2    EPCRA Section 313 Chemical or
      Chemical Category Name
Enter the  name  of  the  EPCRA  Section  313
chemical or chemical category exactly as it appears
in Table II. If the EPCRA Section 313  chemical
name is followed by a synonym in (parentheses),
report the  chemical by  the  name  that directly
follows the CAS number (i.e., not the synonym). If
the  EPCRA  Section 313 chemical  identity  is
actually a product trade name (e.g., dicofol), the
9th  Collective Index  name is listed below it  in
brackets. You  may report either name in this  case.
Do  not list the name of a chemical that does not
appear in Table II, such as individual members  of
an  EPCRA Section 313 chemical category. For
example,  if you use silver chloride, do not report
silver chloride with its CAS number. Report this
chemical as "silver compounds" with its category
code N740.

If you are making a trade secret claim, you must
report the  specific EPCRA Section 313  chemical
identity   on  your  unsanitized  Form  A  and
unsanitized substantiation form.  Do not report the
name of the EPCRA Section 313 chemical on your
sanitized Form A or sanitized substantiation form.
Include a generic name  in Part  II, Section  1.3  of
your sanitized Form A.
                     Toxics Release Inventory Reporting Forms and Instructions
                                          83

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1.3   Generic Chemical Name
Complete Section 1.3 only if you are claiming the
specific EPCRA  Section 313 chemical identity of
the EPCRA Section 313 chemical as a trade secret
and have marked the trade secret block in Part I,
Section  2.1 on Page 1 of Form A. Enter a generic
chemical name that is descriptive of the chemical
structure. You should limit the generic  name to
seventy  characters (e.g., numbers, letters, spaces,
punctuation) or less. Do not enter mixture names in
Section  1.3; see Section 2 below.

In house plant codes  and other substitute names
that are  not structurally descriptive of the EPCRA
Section  313  chemical identity being withheld as a
trade secret are not acceptable as a generic name.
The generic name must appear on both  sanitized
and unsanitized Form A, and the name must be the
same as that used on your substantiation forms.
Section 2.   Mixture Component
              Identity
Report the  generic name provided to you by your
supplier in  this section if your supplier is claiming
the chemical identity proprietary  or trade  secret.
Do not answer "yes" in Part I, Section 2.1 on Page
                             1 of the form if you complete this section. You do
                             not need to supply trade secret substantiation forms
                             for this EPCRA Section 313 chemical because it is
                             your supplier who is claiming the chemical identity
                             a trade secret

                             2.1   Generic Chemical Name Provided by
                                   Supplier
                             Enter the  generic chemical name in this section
                             only if the following three conditions apply:

                             1.   You determine that the mixture contains an
                                 EPCRA Section 313  chemical  but  the only
                                 identity  you have  for that  chemical  is  a
                                 generic name;
                             2.   You know either the specific concentration of
                                 that EPCRA Section 313 chemical component
                                 or a maximum or average concentration level;
                                 and
                             3.   You multiply the concentration level by the
                                 total  annual  amount  of the  whole  mixture
                                 processed or otherwise used and determine
                                 that you meet  the process or otherwise use
                                 threshold for that single, generically identified
                                 mixture component.
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                      Facility Eligibility Determination for Alternate Threshold
                      and for Reporting on EPA Form A Certification Statement
                                            Index
Ancillary or other use, 38
article component, 37
byproduct, 37
Catastrophic Events, 67, 69
CD, 1
CDX, vii, 2, 6, 83
chemical processing aid, 38
Coal Extraction Activities Exemption, 20
Coincidental Manufacture, 11, 12
Container Residue, 52
De Minimis Exemption, 16
Discharges to Receiving Streams or Water
  Bodies, 41
Disposal to  Land, 42
Dun & Bradstreet, 34, 84
Energy Recovery, 54, 57, 61, 62, 64
EPA Identification Number,  49, 50
EPCRA, vi, vii, viii, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11,
  12,  13, 14, 15,  16, 17, 18,  20, 21, 22, 23, 24, 25,
  26, 27, 28, 29,  30, 31, 32,  33, 34, 35, 36, 37, 38,
  39, 40, 41, 42,  43, 44, 45,  46, 48, 49, 50, 51, 52,
  53, 54, 57, 59,  60, 61, 62,  63, 64, 65, 66, 67, 68,
  69, 70, 72, 73,  74, 75, 80,  82, 85, 86
Facility Identification, 82
Form A, 79
formulation component, 37
Fugitive or Non-Point Air Emissions, 41
Full-Time Employee, 7
Import, 37
impurity, 37
Laboratory Activities Exemption, 20
Manufacture, 11, 13, 18, 20,  37
manufacturing aid, 38
Metal Category Compounds, 24
Metal Mining Overburden Exemption, 21
Mixture Component Identity, 27
Nitrate Compounds, 26
On-Site Recycling Codes, 62
Other Disposal, 43
Other Surface Impoundments, 43
Otherwise Use, 11, 13, 15, 18, 37
PBT, 8, 13, 14, 15,  16, 17, 18, 21, 22, 23, 25, 28,
  29, 30, 31, 36, 39, 40, 41, 43, 48, 49, 50, 51, 62,
  64,68
Process, 4, 11, 13, 18,37
Produce, 37
Production Ratio, 71
RCRA Subtitle C landfills, 42
RCRA Subtitle C Surface Impoundments, 43
reactant, 37
Repackaging, 37
Reporting Year, 28, 29, 30, 31, 65
Revise, 4
sale/distribution, 37
Source Reduction, 64, 74
Storm water Runoff, 48
Submit Paper Form R, 2
Surface Impoundments, 43
Technical Contact,  6, 33, 83
Threshold Determinations, 21
Total Transfers, 49
Toxics Release Inventory Assistance Library
  (TRIAL), vii
Trade Secret, 2, 32, 82
TRI-ME, vii, 1, 32,  83
Underground Injection, 42, 55
Waste Treatment Codes, 60
Withdraw, 4, 5
                      Toxics Release Inventory Reporting Forms and Instructions
                                          85

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                             Table 1.NAICS Codes
1.1   NAICS codes that
       correspond to SIC codes 20
       through 39:
 113310 Logging
 311     Food Manufacturing
 3111    Animal Food Manufacturing

 31111   Animal Food Manufacturing

 311111    Dog and Cat Food Manufacturing

 311119    Other Animal Food Manufacturing (except
         facilities primarily engaged in Custom Grain
         Grinding for Animal Feed)

 3112    Grain and Oilseed Milling

 31121   Flour Milling and Malt
         Manufacturing

 311211    Flour Milling

 311212    Rice Milling

 311213    Malt Manufacturing

 31122   Starch  and Vegetable Fats and
         Oils Manufacturing

 311221    Wet Corn Milling

 311222    Soybean Processing

 311223    Other Oilseed Processing

 311225    Fats and Oils Refining and Blending

 31123   Breakfast Cereal Manuf.

 311230    Breakfast Cereal Manufacturing

 3113    Sugar and Confectionery
         Product Manufacturing

 31131   Sugar Manufacturing

 311311    Sugarcane Mills

 311312    Cane Sugar Refining

 311313    Beet Sugar Manufacturing
31132  Chocolate and Confectionery
        Manufacturing from Cacao
        Beans

311320   Chocolate and Confectionery Manufacturing
        from Cacao Beans

31133  Confectionery Manufacturing
        from Purchased Chocolate

311330   Confectionery Manufacturing from Purchased
        Chocolate (except facilities primarily
        engaged in the retail sale of candy, nuts,
        popcorn and other confections not for
        immediate consumption made on the
        premises)

31134  Nonchocolate Confectionery
        Manufacturing

311340   Nonchocolate Confectionery Manufacturing
        (except facilities primarily engaged in the
        retail sale of candy, nuts, popcorn and other
        confections not for immediate consumption
        made on the premises)

3114   Fruit and Vegetable
        Preserving and Specialty Food
        Manufacturing

31141  Frozen Food Manufacturing

311412   Frozen Specialty Food Manufacturing

31142  Fruit and Vegetable Canning,
        Pickling and Drying

311421   Fruit and Vegetable Canning

311422   Specialty Canning

311423   Dried and Dehydrated Food Manufacturing

3115   Dairy Product Manufacturing

31151  Dairy Product (except Frozen)
        Manufacturing

311511   Fluid Milk Manufacturing

311512   Creamery Butter Manufacturing

311513   Cheese Manufacturing

311514   Dry, Condensed, and Evaporated Dairy
        Product Manufacturing
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                                   Table I. NAICS Codes
 31152   Ice Cream and Frozen Dessert
          Manufacturing
 311520    Ice Cream and Frozen Dessert Manufacturing
 3116    Animal Slaughtering and
          Processing
 31161   Animal Slaughtering and
          Processing
 311611    Animal (except Poultry) Slaughtering (except
          for facilities primarily engaged in Custom
          Slaughtering for individuals)
 311612    Meat Processed from Carcasses [except for
          facilities primarily engaged in the cutting up
          and resale of purchased fresh carcasses for the
          trade (including boxed beef)]
 311613    Rendering and Meat Byproduct Processing
 311615    Poultry Processing
 3117    Seafood Product Preparation
          and Packaging
 311711    Seafood Canning
 311712    Fresh and Frozen  Seafood Processing
 3118    Bakeries and Tortilla
          Manufacturing
 31181   Bread and Bakery Product
          Manufacturing
 311812    Commercial Bakeries
 311813    Frozen Cakes, Pies, and Other Pastries
          Manufacturing
 31182   Cookie, Cracker, and Pasta
          Manufacturing
 311821    Cookie and Cracker Manufacturing
 311822    Flour Mixes and Dough Manufacturing from
          Purchased Flour
 311823    Dry Pasta Manufacturing
 31183   Tortilla Manufacturing
 311830    Tortilla Manufacturing
 3119    Other Food Manufacturing
 31191   Snack Food Manufacturing
                             311911    Roasted Nuts and Peanut Butter
                                     Manufacturing
                             311919    Other Snack Food Manufacturing
                              31192  Coffee and Tea
                                     Manufacturing
                              311920   Coffee and Tea Manufacturing
                              31193  Flavoring Syrup and
                                     Concentrate Manufacturing
                              311930   Flavoring Syrup and Concentrate
                                     Manufacturing
                              31194  Seasoning and Dressing
                                     Manufacturing
                              311941   Mayonnaise, Dressing, and Other Prepared
                                     Sauce Manufacturing
                              311942   Spice and Extract Manufacturing
                              31199  All Other Miscellaneous Food
                                     Manufacturing
                              311991   Perishable Prepared Food Manufacturing
                              311999   All Other Miscellaneous Food
                                     Manufacturing
                             312      Beverage and Tobacco
                                      Product Manufacturing
                              3121    Beverage Manufacturing
                             31211   Soft Drink and Ice
                                      Manufacturing
                              312111   Soft Drink Manufacturing
                              312112   Bottled Water Manufacturing (except
                                      facilities primarily engaged in bottling
                                      mineral or spring water)
                              312113   Ice Manufacturing
                              31212  Breweries
                              312120   Breweries
                             31213   Wineries
                              312130   Wineries
                              31214  Distilleries
                              312140   Distilleries
1-2
Toxics Release Inventory Reporting Form and Instructions

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                                 Table I. NAICS Codes
 3122    Tobacco Manufacturing
 31221  Tobacco Stemming and
        Redrying
 312210   Tobacco Stemming and Redrying
 31222  Tobacco Product
        Manufacturing
 312221   Cigarette Manufacturing
 312229   Other Tobacco Product Manufacturing
        (except for facilities primarily engaged in
        providing Tobacco Sheeting Services)
 313     Textile Mills
 3131    Fiber, Yarn, and Thread
         Mills
 31311  Fiber, Yarn, and Thread
         Mills
 313111   Yarn Spinning Mills
 313112   Yarn Texturizing, Throwing, and Twisting
         Mills
 313113   Thread Mills
3132    Fabric Mills
31321   Broadwoven Fabric Mills
313210    Broadwoven Fabric Mills
31322   Narrow Fabric Mills and
         Schiffli Machine Embroidery
313221    Narrow Fabric Mills
313222    Schiffli Machine Embroidery
31323   Nonwoven Fabric Mills
313230    Nonwoven Fabric Mills
31324   Knit Fabric Mills
313241    Weft Knit Fabric Mills
313249    Other Knit Fabric and Lace Mills
3133    Textile and Fabric Finishing
         and Fabric Coating Mills
31331
313311
313312
31332
313320
314
3141
31411
314110
31412
314121
314129
3149
31491
314911
314912
31499
314991
314992
314999
315
Textile and Fabric Finishing
Mills
Broadwoven Fabric Finishing Mills (except
facilities primarily engaged in converting
broadwoven piece goods and broadwoven
textiles and facilities primarily engaged in
sponging fabric for tailors and dressmakers)
Textile and Fabric Finishing (except
Broadwoven Fabric) Mills (except facilities
primarily engaged in converting narrow
woven textiles and narrow woven piece
goods)
Fabric Coating Mills
Fabric Coating Mills
Textile Product Mills
Textile Furnishing Mills
Carpet and Rug Mills
Carpet and Rug Mills
Curtain and Linen Mills
Curtain and Drapery Mills (except facilities
primarily engaged in making custom drapery
for retail sale)
Other Household Textile Product Mills
(except facilities primarily engaged in making
custom drapery for retail sale)
Other Textile Product Mills
Textile Bag and Canvas Mills
Textile Bag Mills
Canvas and Related Product Mills
All Other Textile Product
Mills
Rope, Cordage, and Twine Mills
Tire Cord and Tire Fabric Mills
All Other Miscellaneous Textile Product
Mills (except facilities engaged in binding
carpets and rugs for the trade, carpet cutting
and binding, and embroidering on textile
products (except apparel) for the trade)
Apparel Manufacturing
                  Toxics Release Inventory Reporting Form and Instructions
1-3

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                                    Table I. NAICS Codes

3151
31511

315111

315119
31519

315191

315192
3152

31521

315211

315212

31522

315221

315222



315223


315224

315225
315228

31523

315231

315232


Apparel Knitting Mills
Hosiery and Sock Mills
•7
Sheer Hosiery Mills

Other Hosiery and Sock Mills
Other Apparel Knitting Mills

Outerwear Knitting Mills

Underwear and Nightwear Knitting Mills
Cut and Sew Apparel
Manufacturing
Cut and Sew Apparel
Contractors
Men's and Boys' Cut and Sew Apparel
Contractors
Women's, Girls', and Infants' Cut and Sew
Apparel Contractors

Men's and Boys' Cut and Sew
«/
Apparel Manufacturing
Men's and Boys' Cut and Sew Underwear
and Nightwear Manufacturing
Men's and Boys' Cut and Sew Suit, Coat, and
Overcoat Manufacturing (except custom
tailors primarily engaged in making and
selling men's and boy's suits, cut and sewn
from purchased fabric)
Men's and Boys' Cut and Sew Shirt (except
Work Shirt) Manufacturing (except custom
tailors primarily engaged in making and
selling men's and boy's dress shirts, cut and
sewn from purchased fabric)
Men's and Boys' Cut and Sew Trouser,
Slack, and Jean Manufacturing
Men's and Boys' Cut and Sew Work Clothing
Manufacturing
Men's and Boys' Cut and Sew Other
Outerwear Manufacturing
Women's and Girls' Cut and
Sew Apparel Manufacturing

Women's and Girls' Cut and Sew Lingerie,
Loungewear, and Nightwear Manufacturing
Women's and Girls' Cut and Sew Blouse and
Shirt Manufacturing









































315233





315234


315239

31529

315291
315292
315299

3159


31599

315991
315992
315993
315999

316

3161

31611

316110
3162
31621
316211

316212
316213

Women's and Girls' Cut and Sew Dress
Manufacturing (except custom tailors
primarily engaged in making and selling
bridal dresses or gowns, or women's, misses'
and girls' dresses cut and sewn from
purchased fabric (except apparel contractors)
(custom dressmakers)
Women's and Girls' Cut and Sew Suit, Coat,
Tailored Jacket, and Skirt Manufacturing

Women's and Girls' Cut and Sew Other
Outerwear Manufacturing
Other Cut and Sew Apparel
Manufacturing
Infants' Cut and Sew Apparel Manufacturing
Fur and Leather Apparel Manufacturing
All Other Cut and Sew Apparel
Manufacturing
Apparel Accessories and
Other Apparel Manufacturing

Apparel Accessories and
Other Apparel Manufacturing

Hat, Cap, and Millinery Manufacturing
Glove and Mitten Manufacturing
Men's and Boys' Neckwear Manufacturing
Other Apparel Accessories and Other Apparel
Manufacturing
Leather and Allied Product
Manufacturing

Leather and Hide Tanning
and Finishing
Leather and Hide Tanning
and Finishing
Leather and Hide Tanning and Finishing
Footwear Manufacturing
Footwear Manufacturing
Rubber and Plastics Footwear Manufacturing

House Slipper Manufacturing
Men's Footwear (except Athletic)
Manufacturing
1-4
Toxics Release Inventory Reporting Form and Instructions

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                                  Table I. NAICS Codes
316214    Women's Footwear (except Athletic)
         Manufacturing
316219    Other Footwear Manufacturing
3169    Other Leather and Allied
         Product Manufacturing
31699   Other Leather and Allied
         Product Manufacturing
316991    Luggage Manufacturing
316992    Women's Handbag and Purse Manufacturing
316993    Personal Leather Good (except Women's
         Handbag and Purse) Manufacturing
316999    All Other Leather Good Manufacturing
321      Wood Product Manufacturing
3211    Sawmills and Wood
         Preservation
321113    Sawmills
321114    Wood Preservation
3212    Veneer, Plywood, and
         Engineered Wood Product
         Manufacturing
32121   Veneer, Plywood, and
         Engineered Wood Product
         Manufacturing
321211    Hardwood Veneer and Plywood
         Manufacturing
321212    Softwood Veneer and Plywood
         Manufacturing
321213    Engineered Wood Member (except Truss)
         Manufacturing
321214    Truss Manufacturing
321219    Reconstituted Wood Product Manufacturing
3219    Other Wood Product
         Manufacturing
32191   Millwork
321911    Wood Window and Door Manufacturing
321912    Cut Stock, Resawing Lumber, and Planing
321918    Other Millwork (including Flooring)
32192   Wood Container and Pallet
         Manufacturing
321920    Wood Container and Pallet Manufacturing
32199   All Other Wood Product
         Manufacturing
321991    Manufactured Home (Mobile Home)
         Manufacturing
321992    Prefabricated Wood Building Manufacturing
321999    All Other Miscellaneous Wood Product
         Manufacturing
322     Paper Manufacturing
3221    Pulp, Paper, and Paperboard
         Mills
32211   Pulp Mills
322110    Pulp Mills
32212   Paper Mills
322121    Paper (except Newsprint) Mills
322122    Newsprint Mills
32213   Paperboard Mills
322130    Paperboard Mills
3222    Converted Paper Product
         Manufacturing
32221   Paperboard Container
         Manufacturing
322211    Corrugated and Solid Fiber Box
         Manufacturing
322212    Folding Paperboard Box Manufacturing
322213    Setup Paperboard Box Manufacturing
322214    Fiber Can, Tube, Drum, and Similar Products
         Manufacturing
322215    Nonfolding Sanitary Food Container
         Manufacturing
32222   Paper Bag and Coated and
         Treated Paper Manufacturing
322221    Coated and Laminated Packaging Paper and
         Plastics Film Manufacturing
                   Toxics Release Inventory Reporting Form and Instructions
                                     1-5

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                                    Table I. NAICS Codes
 322222    Coated and Laminated Paper Manufacturing
 322223    Plastics, Foil, and Coated Paper Bag
          Manufacturing
 322224    Uncoated Paper and Multiwall Bag
          Manufacturing
 322225    Laminated Aluminum Foil Manufacturing for
          Flexible Packaging Uses
 322226    Surface-Coated Paperboard Manufacturing
 32223   Stationery Product
          Manufacturing
 322231    Die-Cut Paper and Paperboard Office
          Supplies
          Manufacturing
 322232    Envelope Manufacturing
 322233    Stationery, Tablet, and Related Product
          Manufacturing
 32229   Other Converted Paper
          Product  Manufacturing
 322291    Sanitary Paper Product Manufacturing
 322299    All Other Converted Paper Product
          Manufacturing
 323     Printing and Related Support
          Activities
 3231    Printing and Related Support
          Activities
 32311   Printing
 323110    Commercial Lithographic Printing
 323113    Commercial Screen Printing
 323114    Quick Printing (except facilities primarily
          engaged in reproducing text, drawings, plans,
          maps, or other copy by blueprinting,
          photocopying, mimeographing, or other
          methods of duplication other than printing or
          microfilming (i.e., instant printing)
 323115    Digital Printing
 323116    Manifold Business Forms Printing
 323117    Books Printing
 323118    Blankbook, Looseleaf Binders, and Devices
          Manufacturing
 323119    Other Commercial Printing
                              32312   Support Activities for Printing
                              323121    Tradebinding and Related Work
                              323122    Prepress Services
                              324     Petroleum and Coal Products
                                       Manufacturing
                              3241    Petroleum and Coal Products
                                       Manufacturing
                              32411   Petroleum Refineries
                              324110    Petroleum Refineries
                              32412   Asphalt Paving, Roofing, and
                                       Saturated Materials
                                       Manufacturing
                              324121    Asphalt Paving Mixture and Block
                                       Manufacturing
                              324122    Asphalt Shingle and Coating Materials
                                       Manufacturing
                              32419   Other Petroleum and Coal
                                       Products Manufacturing
                              324191    Petroleum Lubricating Oil and Grease
                                       Manufacturing
                              324199    All Other Petroleum and Coal Products
                                       Manufacturing
                              325     Chemical Manufacturing
                              3251    Basic Chemical
                                       Manufacturing
                              32511   Petrochemical Manufacturing
                              325110    Petrochemical Manufacturing
                              32512   Industrial Gas  Manufacturing
                              325120    Industrial Gas Manufacturing
                              32513   Synthetic Dye and Pigment
                                       Manufacturing
                              325131    Inorganic Dye and Pigment Manufacturing
                              325132    Synthetic Organic Dye and Pigment
                                       Manufacturing
                              32518   Other Basic Inorganic
                                       Chemical Manufacturing
1-6
Toxics Release Inventory Reporting Form and Instructions

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                                 Table I. NAICS Codes
325181   Alkalies and Chlorine Manufacturing
325182   Carbon Black Manufacturing
325188   All Other Basic Inorganic Chemical
        Manufacturing
32519  Other Basic Organic Chemical
        Manufacturing
325191   Gum and Wood Chemical Manufacturing
325192   Cyclic Crude and Intermediate Manufacturing
325193   Ethyl Alcohol Manufacturing
325199   All Other Basic Organic Chemical
        Manufacturing
3252   Resin, Synthetic Rubber, and
        Artificial Synthetic Fibers and
        Filaments Manufacturing
32521  Resin and Synthetic Rubber
        Manufacturing
325211   Plastics Material and Resin Manufacturing
325212   Synthetic Rubber Manufacturing
32522  Artificial and Synthetic Fibers
        and Filaments Manufacturing
325221   Cellulosic Organic Fiber Manufacturing
325222   Noncellulosic Organic Fiber Manufacturing
3253   Pesticide, Fertilizer, and Other
        Agricultural Chemical
        Manufacturing
32531  Fertilizer Manufacturing
325311   Nitrogenous Fertilizer Manufacturing
325312   Phosphatic Fertilizer Manufacturing
325314   Fertilizer (Mixing Only) Manufacturing
32532  Pesticide and Other
        Agricultural Chemical
        Manufacturing
325320   Pesticide and Other Agricultural Chemical
        Manufacturing
3254   Pharmaceutical and Medicine
        Manufacturing
32541  Pharmaceutical and Medicine
        Manufacturing
325411   Medicinal and Botanical Manufacturing
325412   Pharmaceutical Preparation Manufacturing
325413   In-Vitro Diagnostic Substance Manufacturing
325414   Biological Product (except Diagnostic)
        Manufacturing
3255    Paint, Coating, and Adhesive
        Manufacturing
32551  Paint and Coating
        Manufacturing
325510   Paint and Coating Manufacturing
32552  Adhesive Manufacturing
325520   Adhesive Manufacturing
3256    Soap, Cleaning Compound,
        and Toilet Preparation
        Manufacturing
32561  Soap and Cleaning Compound
        Manufacturing
325611   Soap and Other Detergent Manufacturing
325612   Polish and Other Sanitation Good
        Manufacturing
'325613   Surface Active Agent Manufacturing
32562  Toilet Preparation
        Manufacturing
325620   Toilet Preparation Manufacturing
3259    Other Chemical Product and
        Preparation Manufacturing
32591  Printing Ink Manufacturing
325910   Printing Ink Manufacturing
32592  Explosives Manufacturing
325920   Explosives Manufacturing
32599  All Other Chemical Product
        and Preparation
        Manufacturing
                  Toxics Release Inventory Reporting Form and Instructions
                                    1-7

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                                    Table I. NAICS Codes
 325991    Custom Compounding of Purchased Resins
 325992    Photographic Film, Paper, Plate, and
          Chemical
          Manufacturing
 325998    All Other Miscellaneous Chemical Product
          and Preparation Manufacturing (except
          facilities primarily engaged in Aerosol can
          filling on a job order or contract Basis)
 326      Plastics and Rubber Products
          Manufacturing
 3261    Plastics Product
          Manufacturing
 32611   Plastics Packaging Materials
          and Unlaminated Film and
          Sheet Manufacturing
 326111    Plastics Bag Manufacturing
 326112    Plastics Packaging Film and Sheet (including
          Laminated) Manufacturing
 326113    Unlaminated Plastics Film and Sheet (except
          Packaging) Manufacturing
 32612   Plastics, Pipe, Pipe Fitting, and
          Unlaminated Profile Shape
          Manufacturing
 326121    Unlaminated Plastics Profile Shape
          Manufacturing
 326122    Plastics Pipe and Pipe Fitting Manufacturing
 32613   Laminated Plastics Plate,
          Sheet
          (except Packaging), and Shape
          Manufacturing
 326130    Laminated Plastics Plate, Sheet (except
          Packaging), and Shape Manufacturing
 32614   Polystyrene Foam Product
          Manufacturing
 326140    Polystyrene Foam Product Manufacturing
 32615   Urethane and Other Foam
          Product (except Polystyrene)
          Manufacturing
                             326150   Urethane and Other Foam Product (except
                                      Polystyrene) Manufacturing
                             32616  Plastics Bottle Manufacturing
                             326160   Plastics Bottle Manufacturing
                             32619  Other Plastics Product
                                      Manufacturing
                             326191   Plastics Plumbing Fixture Manufacturing
                             326192   Resilient Floor Covering Manufacturing
                             326199   All Other Plastics Product Manufacturing
                             3262    Rubber Product
                                      Manufacturing

                             32621  Tire Manufacturing
                             326211   Tire Manufacturing (except Retreading)

                             32622  Rubber and Plastics Hoses and
                                      Belting Manufacturing
                             326220   Rubber and Plastics Hoses and Belting
                                      Manufacturing
                             32629  Other Rubber Product
                                      Manufacturing
                             326291   Rubber Product Manufacturing for
                                      Mechanical Use
                             326299   All Other Rubber Product Manufacturing
                             327     Nonmetallic Mineral Product
                                      Manufacturing
                             3271    Clay Product and Refractory
                                      Manufacturing

                             32711  Pottery, Ceramics, and
                                      Plumbing Fixture
                                      Manufacturing
                             327111   Vitreous China Plumbing Fixture and China
                                      and Earthenware Bathroom Accessories
                                      Manufacturing
                             327112   Vitreous China, Fine Earthenware, and Other
                                      Pottery Product Manufacturing (except
                                      facilities primarily engaged in manufacturing
                                      and selling pottery on site)
                             327113   Porcelain Electrical Supply Manufacturing
1-8
Toxics Release Inventory Reporting Form and Instructions

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                                 Table I. NAICS Codes
32712  Clay Building Material and
        Refractories Manufacturing
327121   Brick and Structural Clay Tile Manufacturing
327122   Ceramic Wall and Floor Tile Manufacturing
327123   Other Structural Clay Product Manufacturing
327124   Clay Refractory Manufacturing
327125   Nonclay Refractory Manufacturing
3272    Glass and Glass Product
        Manufacturing

32721  Glass and Glass Product
        Manufacturing
327211   Flat Glass Manufacturing
327212   Other Pressed and Blown Glass and
        Glassware Manufacturing
327213   Glass Container Manufacturing
327215   Glass Product Manufacturing Made of
        Purchased Glass
3273    Cement and Concrete Product
        Manufacturing
32731  Cement Manufacturing
327310   Cement Manufacturing
32732  Ready-Mix Concrete
        Manufacturing
327320   Ready-Mix Concrete Manufacturing
32733  Concrete, Pipe, Brick, and
        Block Manufacturing
327331   Concrete Block and Brick Manufacturing
327332   Concrete Pipe Manufacturing
32739  Other Concrete Product
        Manufacturing
327390   Other Concrete Product Manufacturing
3274    Lime and Gypsum Product
        Manufacturing
32741  Lime Manufacturing
327410   Lime Manufacturing
32742  Gypsum Product
        Manufacturing
327420   Gypsum Product Manufacturing
3279   Other Nonmetallic Mineral
        Product Manufacturing

32791  Abrasive Product
        Manufacturing
327910   Abrasive Product Manufacturing
32799  All Other Nonmetallic Mineral
        Product Manufacturing
327991   Cut Stone and Stone Product Manufacturing
327992   Ground or Treated Mineral and Earth
        Manufacturing
327993   Mineral Wool Manufacturing
327999   All Other Miscellaneous Nonmetallic Mineral
        Product Manufacturing
331     Primary Metal Manufacturing
3311   Iron and Steel Mills and
        Ferroalloy Manufacturing
33111  Iron and Steel Mills and
        Ferroalloy Manufacturing
331111   Iron and Steel Mills
331112   Electrometallurgical Ferroalloy Product
        Manufacturing
3312   Steel Product Manufacturing
        from Purchased Steel
33121  Iron and Steel Pipe and Tube
        Manufacturing from
        Purchased Steel
331210   Iron and Steel Pipe and Tube Manufacturing
        from Purchased Steel
33122  Rolling and Drawing of
        Purchased Steel
331221   Rolled Steel Shape Manufacturing
331222   Steel Wire Drawing
                  Toxics Release Inventory Reporting Form and Instructions
                                    1-9

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                                   Table I. NAICS Codes
 3313   Alumina and Aluminum
         Production and Processing
 33131  Alumina and Aluminum
         Production and Processing
 331311   Alumina Refining
 331312   Primary Aluminum Production
 331314   Secondary Smelting and Alloying of
         Aluminum
 331315   Aluminum Sheet, Plate, and Foil
         Manufacturing
 331316   Aluminum Extruded Product Manufacturing
 331319   Other Aluminum Rolling and Drawing
 3314   Nonferrous Metal (except
         Aluminum) Production and
         Processing
 33141  Nonferrous Metal (except
         Aluminum) Smelting and
         Refining
 331411   Primary Smelting and Refining of Copper
 331419   Primary Smelting and Refining of Nonferrous
         Metal (except Copper and Aluminum)
 33142  Copper Rolling, Drawing,
         Extruding and Alloying
 331421   Copper Rolling, Drawing, and Extruding
 331422   Copper Wire (except Mechanical) Drawing
 331423   Secondary Smelting, Refining, and Alloying
         of Copper
 33149  Nonferrous Metal (except
         Copper and Aluminum)
         Rolling, Drawing, Extruding,
         and Alloying
 331491   Nonferrous Metal (except Copper and
         Aluminum) Rolling, Drawing, and Extruding
 331492   Secondary Smelting, Refining, and Alloying
         of
         Nonferrous Metal (except Copper and
         Aluminum)
 3315   Foundries
                             33151   Ferrous Metal Foundries
                             331511    Iron Foundries
                             331512    Steel Investment Foundries
                             331513    Steel Foundries (except Investment)
                             33152   Nonferrous Metal Foundries
                             331521    Aluminum Die-Casting Foundries
                             3 31522    Nonferrous (except Aluminum) Die-Casting
                                      Foundries
                             3 31524    Aluminum Foundries (except Die-Casting)
                             331525    Copper Foundries (except Die-Casting)
                             331528    Other Nonferrous Foundries (except Die-
                                      Casting)
                             332     Fabricated Metal Product
                                      Manufacturing
                             3321    Forging and Stamping
                             33211   Forging and Stamping
                             332111    Iron and Steel Forging
                             332112    Nonferrous Forging
                             332114    Custom Roll Forming
                             332115    Crown and Closure Manufacturing
                             332116    Metal Stamping
                             332117    Powder Metallurgy Part Manufacturing
                             3322    Cutlery and Handtool
                                      Manufacturing
                             33221   Cutlery and Handtool
                                      Manufacturing
                             332211    Cutlery and Flatware (except Precious)
                                      Manufacturing
                             332212    Hand and Edge Tool Manufacturing
                             332213    Saw Blade and Handsaw Manufacturing
                             332214    Kitchen Utensil, Pot, and Pan Manufacturing
                             3323    Architectural and Structural
                                      Metals Manufacturing
1-10
Toxics Release Inventory Reporting Form and Instructions

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                                 Table I. NAICS Codes
33231  Plate Work and Fabricated
        Structural Product
        Manufacturing
332311   Prefabricated Metal Building and Component
        Manufacturing
332312   Fabricated Structural Metal Manufacturing
332313   Plate Work Manufacturing
33232  Ornamental and Architectural
        Metal Products
        Manufacturing
332321   Metal Window and Door Manufacturing
332322   Sheet Metal Work Manufacturing
332323   Ornamental and Architectural Metal Work
        Manufacturing
3324    Boiler, Tank, and Shipping
        Container Manufacturing
33241  Power Boiler and Heat
        Exchanger Manufacturing
532410   Power Boiler and Heat Exchanger
        Manufacturing
33242  Metal Tank (Heavy Gauge)
        Manufacturing
332420   Metal Tank (Heavy Gauge) Manufacturing
33243  Metal Can, Box, and Other
        Metal Container (Light
        Gauge) Manufacturing
332431   Metal Can Manufacturing
332439   Other Metal Container Manufacturing
3325    Hardware Manufacturing
33251  Hardware Manufacturing
332510   Hardware Manufacturing
3326    Spring and Wire Product
        Manufacturing
33261  Spring and Wire Product
        Manufacturing
332611   Spring (Heavy Gauge) Manufacturing
332612    Spring (Light Gauge) Manufacturing
332618    Other Fabricated Wire Product
         Manufacturing
3327    Machine Shops; Turned
         Product; and Screw, Nut and
         Bolt Manufacturing
33271   Machine Shops
332710    Machine Shops
33272   Turned Product and Screw,
         Nut and Bolt Manufacturing
332721    Precision Turned Product Manufacturing
332722    Bolt, Nut, Screw, Rivet, and Washer
         Manufacturing
3328    Coating, Engraving, Heat
         Treating, and Allied Activities
33281   Coating, Engraving, Heat
         Treating, and Allied Activities
332811    Metal Heat Treating
332812    Metal Coating, Engraving (except Jewelry
         and Silverware), and Allied Services to
         Manufacturers
332813    Electroplating, Plating, Polishing, Anodizing,
         and Coloring
3329    Other Fabricated Metal
         Product Manufacturing
33291   Metal Valve Manufacturing
332911    Industrial Valve Manufacturing
332912    Fluid Power Valve and Hose Fitting
         Manufacturing
332913    Plumbing Fixture Fitting and Trim
         Manufacturing
332919    Other Metal Valve and Pipe Fitting
         Manufacturing
33299   All Other Fabricated Metal
         Product Manufacturing
332991    Ball and Roller Bearing Manufacturing
332992    Small Arms Ammunition Manufacturing
                  Toxics Release Inventory Reporting Form and Instructions
                                     1-11

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                                   Table I. NAICS Codes
 332993    Ammunition (except Small Arms)
          Manufacturing
 332994    Small Arms Manufacturing
 332995    Other Ordnance and Accessories
          Manufacturing
 332996    Fabricated Pipe and Pipe Fitting
          Manufacturing
 332997    Industrial Pattern Manufacturing
 332998    Enameled Iron and Metal Sanitary Ware
          Manufacturing
 332999    All Other Miscellaneous Fabricated Metal
          Product Manufacturing
 333      Machinery Manufacturing
 3331    Agriculture, Construction, and
          Mining Machinery
          Manufacturing
 33311   Agricultural Implement
          Manufacturing
 333111    Farm Machinery and Equipment
          Manufacturing
 333112    Lawn and Garden Tractor and Home Lawn
          and Garden Equipment Manufacturing
 33312   Construction Machinery
          Manufacturing
 333120    Construction Machinery Manufacturing

 33313   Mining and Oil and Gas Field
          Machinery Manufacturing
 333131    Mining Machinery and Equipment
          Manufacturing
 333132    Oil and Gas Field Machinery and Equipment
          Manufacturing
 3332    Industrial Machinery
          Manufacturing
 33321   Sawmill and Woodworking
          Machinery Manufacturing
 333210    Sawmill and Woodworking Machinery
          Manufacturing
                             33322   Plastics and Rubber Industry
                                      Machinery Manufacturing
                             333220    Plastics and Rubber Industry Machinery
                                      Manufacturing
                             33329   Other Industrial Machinery
                                      Manufacturing
                             333291    Paper Industry Machinery Manufacturing
                             333292    Textile Machinery Manufacturing
                             333293    Printing Machinery and Equipment
                                      Manufacturing
                             333294    Food Product Machinery Manufacturing
                             333295    Semiconductor Machinery Manufacturing
                             333298    All Other Industrial Machinery
                                      Manufacturing
                             3333    Commercial and Service
                                      Industry Machinery
                                      Manufacturing
                             33331   Commercial and Service
                                      Industry Machinery
                                      Manufacturing
                             333311    Automatic Vending Machine Manufacturing
                             333312    Commercial Laundry, Drycleaning, and
                                      Pressing Machine Manufacturing
                             333313    Office Machinery Manufacturing
                             333314    Optical Instrument and Lens Manufacturing
                             333315    Photographic and Photocopying Equipment
                                      Manufacturing
                             333319    Other Commercial and Service Industry
                                      Machinery Manufacturing
                             3334    Ventilation, Heating, Air-
                                      Conditioning, and Commercial
                                      Refrigeration
                             33341   Equipment Manufacturing
                                      Ventilation, Heating, Air-
                                      Conditioning, and Commercial
                                      Refrigeration Equipment
                                      Manufacturing
                             333411    Air Purification Equipment Manufacturing
1-12
Toxics Release Inventory Reporting Form and Instructions

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                                   Table I. NAICS Codes
333412    Industrial and Commercial Fan and Blower
         Manufacturing

333414    Heating Equipment (except Warm Air
         Furnaces) Manufacturing

333415    Air-Conditioning and Warm Air Heating
         Equipment and Commercial and Industrial
         Refrigeration Equipment Manufacturing

3335    Metalworking Machinery
         Manufacturing

33351   Metalworking Machinery
         Manufacturing

333511    Industrial Mold Manufacturing

333512    Machine Tool (Metal Cutting Types)
         Manufacturing

333513    Machine Tool (Metal Forming Types)
         Manufacturing

333514    Special Die and Tool, Die Set, Jig, and
         Fixture Manufacturing

333515    Cutting Tool and Machine Tool Accessory
         Manufacturing

333516    Rolling Mill Machinery and Equipment
         Manufacturing

333518    Other Metalworking Machinery
         Manufacturing

3336    Engine, Turbine, and Power
         Transmission Equipment
         Manufacturing

33361   Engine, Turbine, and Power
         Transmission Equipment
         Manufacturing

333611    Turbine and Turbine Generator Set Units
         Manufacturing

333612    Speed Changer, Industrial High-Speed Drive,
         and Gear Manufacturing

333613    Mechanical Power Transmission Equipment
         Manufacturing

 33618    Other Engine Equipment Manufacturing

3339    Other General Purpose
         Machinery Manufacturing
33391   Pump and Compressor
         Manufacturing

333911    Pump and Pumping Equipment
         Manufacturing

333912    Air and Gas Compressor Manufacturing

333913    Measuring and Dispensing Pump
         Manufacturing

33392   Material Handling Equipment
         Manufacturing

333921    Elevator and Moving Stairway Manufacturing

333922    Conveyor and Conveying Equipment
         Manufacturing

333923    Overhead Traveling Crane, Hoist, and
         Monorail System Manufacturing

333924    Industrial Truck, Tractor, Trailer, and Stacker
         Machinery Manufacturing

33399   All Other General Purpose
         Machinery Manufacturing

333991    Power-Driven Handtool Manufacturing

3 3 3 992    Welding and Soldering Equipment
         Manufacturing

333993    Packaging Machinery Manufacturing

3 3 3 994    Industrial Process Furnace and Oven
         Manufacturing

333995    Fluid Power Cylinder and Actuator
         Manufacturing

3 3 3 996    Fluid Power Pump and Motor Manufacturing

3 3 3 997    Scale and Balance Manufacturing

333999    All Other Miscellaneous General Purpose
         Machinery Manufacturing
334     Computer and Electronic
         Product Manufacturing
3341    Computer and Peripheral
         Equipment Manufacturing

33411   Computer and Peripheral
         Equipment Manufacturing

334111    Electronic Computer Manufacturing
334112    Computer Storage Device Manufacturing
                   Toxics Release Inventory Reporting Form and Instructions
                                       1-13

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                                    Table I. NAICS Codes
334113
334119

3342

33421

334210
33422



334220



33429


334290

3343

33431

334310
3344



33441

334411
334412
334413

334414

334415
334416
Computer Terminal Manufacturing
Other Computer Peripheral Equipment
Manufacturing
Communications Equipment
Manufacturing
Telephone Apparatus
Manufacturing
Telephone Apparatus Manufacturing
Radio and Television
Broadcasting and Wireless
Communications Equipment
_E j.
Manufacturing

Radio and Television Broadcasting and
Wireless Communications Equipment
Manufacturing

Other Communications
Equipment Manufacturing

Other Communications Equipment
A /I -C 4-
Manufacturing
Audio and Video Equipment
Manufacturing
Audio and Video Equipment
Manufacturing
Audio and Video Equipment Manufacturing
Semiconductor and Other
Electronic Component
Manufacturing

Semiconductor and Other
Electronic Component
Manufacturing
Electron Tube Manufacturing
Bare Printed Circuit Board Manufacturing
Semiconductor and Related Device
Manufacturing
Electronic Capacitor Manufacturing

Electronic Resistor Manufacturing
Electronic Coil, Transformer, and Other
Inductor Manufacturing







































334417
334418

334419
3345


33451

334510

334511



334512


334513


334514

334515
334516

334517
334518
334519


3346

33461

334612



Electronic Connector Manufacturing
Printed Circuit Assembly (Electronic
Assembly) Manufacturing
Other Electronic Component Manufacturing
Navigational, Measuring,
Electro medical, and Control
Instruments Manufacturing
Navigational, Measuring,
Electro medical, and Control
Instruments Manufacturing
Electromedical and Electrotherapeutic
Apparatus Manufacturing
Search, Detection, Navigation, Guidance,
Aeronautical, and Nautical System and
Instrument Manufacturing

Automatic Environmental Control
Manufacturing for Residential, Commercial,
and Appliance Use
Instruments and Related Products
Manufacturing for Measuring, Displaying,
and Controlling Industrial Process Variables
Totalizing Fluid Meter and Counting Device
Manufacturing
Instrument Manufacturing for Measuring and
Testing Electricity and Electrical Signals
Analytical Laboratory Instrument
Manufacturing
Irradiation Apparatus Manufacturing
Watch, Clock, and Part Manufacturing
Other Measuring and Controlling Device
Manufacturing

Manufacturing and
Reproducing Magnetic and
Optical Media

Manufacturing and
Reproducing Magnetic and
Optical Media
Prerecorded Compact Disc (except Software),
Tape, and Record Reproducing (except
facilities primarily engaged in mass
reproducing pre-recorded Video Cassettes,
and mass reproducing Video tape or disk)
1-14
Toxics Release Inventory Reporting Form and Instructions

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                Table I. NAICS Codes
334613 Magnetic and Optical Recording Media
Manufacturing
335 Electrical Equipment,
Appliance, and Component
Manufacturing
3351 Electric Lighting Equipment
Manufacturing
33511 Electric Lamp Bulb and Part
j.
Manufacturing
335110 Electric Lamp Bulb and Part Manufacturing
33512 Lighting Fixture
Manufacturing
335121 Residential Electric Lighting Fixture
Manufacturing
335122 Commercial, Industrial, and Institutional
Electric Lighting Fixture Manufacturing
335 129 Other Lighting Equipment Manufacturing
3352 Household Appliance
Manufacturing
33521 Small Electrical Appliance
Manufacturing
335211 Electric Housewares and Household Fan
Manufacturing
335212 Household Vacuum Cleaner Manufacturing
33522 Major Appliance
Manufacturing
3 3 522 1 Household Cooking Appliance
Manufacturing
3 3 5222 Household Refrigerator and Home Freezer
Manufacturing
3 3 5224 Household Laundry Equipment
Manufacturing
335228 Other Major Household Appliance
Manufacturing
3353 Electrical Equipment
Manufacturing
33531 Electrical Equipment
Manufacturing



































335311 Power, Distribution, and Specialty
Transformer Manufacturing
335312 Motor and Generator Manufacturing (except
facilities primarily engaged in armature
rewinding on a factory basis)
335313 Switchgear and Switchboard Apparatus
Manufacturing
335314 Relay and Industrial Control Manufacturing
3359 Other Electrical Equipment
and Component
Manufacturing

33591 Battery Manufacturing
33591 1 Storage Battery Manufacturing
335912 Primary Battery Manufacturing
33592 Communication and Energy
Wire and Cable
Manufacturing
335921 Fiber Optic Cable Manufacturing
335929 Other Communication and Energy Wire
Manufacturing
33593 Wiring Device Manufacturing
335931 Current-Carrying Wiring Device
Manufacturing
335932 Noncurrent-Carrying Wiring Device
Manufacturing
33599 All Other Electrical
Equipment
and Component
Manufacturing
335991 Carbon and Graphite Product Manufacturing
335999 All Other Miscellaneous Electrical
Equipment and Component Manufacturing
336 Transportation Equipment
Manufacturing
3361 Motor Vehicle Manufacturing
33611 Automobile and Light Duty
Motor Vehicle Manufacturing
336111 Automobile Manufacturing
Toxics Release Inventory Reporting Form and Instructions
1-15

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                                  Table I. NAICS Codes
336112    Light Track and Utility Vehicle
         Manufacturing
33612   Heavy Duty Truck
         Manufacturing
336120    Heavy Duty Track Manufacturing
3362    Motor Vehicle Body and
         Trailer Manufacturing
33621   Motor Vehicle Body and
         Trailer Manufacturing
336211    Motor Vehicle Body Manufacturing
336212    Track Trailer Manufacturing
336213    Motor Home Manufacturing
336214    Travel Trailer and Camper Manufacturing
3363    Motor Vehicle Parts
         Manufacturing
33631   Motor Vehicle Gasoline
         Engine and Engine Parts
         Manufacturing
336311    Carburetor, Piston, Piston Ring, and Valve
         Manufacturing
336312    Gasoline Engine and Engine Parts
         Manufacturing
33632   Motor Vehicle Electrical and
         Electronic Equipment
         Manufacturing
336321    Vehicular Lighting Equipment Manufacturing
336322    Other Motor Vehicle Electrical and Electronic
         Equipment Manufacturing
33633   Motor Vehicle Steering and
         Suspension Components
         (except Spring)
         Manufacturing
336330    Motor Vehicle Steering and Suspension
         Components (except Spring) Manufacturing
33634   Motor Vehicle Brake System
         Manufacturing
336340    Motor Vehicle Brake System Manufacturing
                                                33635   Motor Vehicle Transmission
                                                         and Power Train Parts
                                                         Manufacturing
                                                336350    Motor Vehicle Transmission and Power Train
                                                         Parts Manufacturing
                                                33636   Motor Vehicle Seating and
                                                         Interior Trim Manufacturing
                                                336360    Motor Vehicle Seating and Interior Trim
                                                         Manufacturing
                                                33637   Motor Vehicle Metal Stamping
                                                336370    Motor Vehicle Metal Stamping
                                                33639   Other Motor Vehicle Parts
                                                         Manufacturing
                                                336391    Motor Vehicle Air-Conditioning
                                                         Manufacturing
                                                336399    All Other Motor Vehicle Parts Manufacturing
                                                3364    Aerospace Product and Parts
                                                         Manufacturing
                                                33641   Aerospace Product and Parts
                                                         Manufacturing
                                                336411    Aircraft Manufacturing
                                                336412    Aircraft Engine and Engine Parts
                                                         Manufacturing
                                                336413    Other Aircraft Parts and Auxiliary Equipment
                                                         Manufacturing
                                                336414    Guided Missile and Space Vehicle
                                                         Manufacturing
                                                336415    Guided Missile and Space Vehicle Propulsion
                                                         Unit and Propulsion Unit Parts Manufacturing
                                                336419    Other Guided Missile and Space Vehicle
                                                         Parts and Auxiliary Equipment
                                                         Manufacturing
                                                3365    Railroad  Rolling Stock
                                                         Manufacturing
                                                33651   Railroad  Rolling Stock
                                                         Manufacturing
                                                336510    Railroad Rolling Stock Manufacturing
                                                3366    Ship and  Boat Building
1-16
                   Toxics Release Inventory Reporting Form and Instructions

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                Table I. NAICS Codes
33661
336611
336612

3369

33699

336991



336992

336999


337

3371

33711

337110


33712

337121



337122


337124
337125


Ship and Boat Building
Ship Building and Repairing
Boat Building

Other Transportation
Equipment Manufacturing
Other Transportation
Equipment Manufacturing
Motorcycle, Bicycle, and Parts

Manufacturing

Military Armored Vehicle, Tank, and Tank
Component Manufacturing

All Other Transportation Equipment
Manufacturing


Furniture and Related
Product Manufacturing
Household and Institutional
Furniture and Kitchen
Cabinet Manufacturing
Wood Kitchen Cabinet and
Countertop Manufacturing

Wood Kitchen Cabinet and Countertop
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom wood
kitchen cabinets and counter tops)
Household and Institutional
Furniture Manufacturing
Upholstered Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture custom made
upholstered household furniture)
Nonupholstered Wood Household Furniture
Manufacturing (except facilities primarily
engaged in the retail sale of household
furniture and that manufacture
nonupholstered, household type, custom
wood furniture)
Metal Household Furniture Manufacturing
Household Furniture (except Wood and
Metal)
Manufacturing


































337127
337129

3372

33721

337211

337212


337214

337215

3379

33791
337910
33792
337920


339
3391

33911

339111
339112

339113
339114





Institutional Furniture Manufacturing
Wood Television, Radio, and Sewing
Machine Cabinet Manufacturing

Office Furniture (including
Fixtures)Manufacturing
Office Furniture (including
Fixtures)Manufacturing
Wood Office Furniture Manufacturing

Custom Architectural Woodwork and

Millwork Manufacturing
Office Furniture (except Wood)
A /I -C 4-
Manufacturing
Showcase, Partition, Shelving, and Locker
Manufacturing
Other Furniture Related
Product Manufacturing
^5
Mattress Manufacturing
Mattress Manufacturing
Blind and Shade
Manufacturing
Blind and Shade Manufacturing


Miscellaneous Manufacturing
Medical Equipment and
Supplies Manufacturing

Medical Equipment and
Supplies Manufacturing

Laboratory Apparatus and Furniture Manuf.
Surgical and Medical Instrument
Manufacturing
Surgical Appliance and Supplies
Manufacturing (except facilities primarily
engaged in manufacturing orthopedic devices
to prescription in a retail environment )
Dental Equipment and Supplies
Manufacturing




Toxics Release Inventory Reporting Form and Instructions
1-17

-------
                                        Table I. NAICS Codes
 339115    Ophthalmic Goods Manufacturing (except
           lens
           grinding facilities that are primarily engaged
           in the retail sale of eyeglasses and contact
           lenses to prescription for individuals)

 3399    Other Miscellaneous
           Manufacturing

 33991   Jewelry and Silverware
           Manufacturing

 339911    Jewelry (except Costume) Manufacturing
 339912    Silverware and Hollowware Manufacturing
 539913    Jewelers' Material and Lapidary Work
           Manufacturing
 339914    Costume Jewelry and Novelty Manufacturing

 33992   Sporting and Athletic Goods
           Manufacturing

 339920    Sporting and Athletic Goods Manufacturing

 33993   Doll, Toy, and Game
           Manufacturing

 339931    Doll and Stuffed Toy Manufacturing
 339932    Game, Toy, and Children's Vehicle
           Manufacturing

 33994   Office Supplies (except Paper)
           Manufacturing

 3 3 9941    Pen and Mechanical Pencil Manufacturing
 3 3 9942    Lead Pencil and Art Good Manufacturing
 3 3 9943    Marking Device Manufacturing
 3 3 9944    Carbon Paper and Inked Ribbon
           Manufacturing

 33995   Sign Manufacturing

 339950    Sign Manufacturing

 33999   All Other Miscellaneous
           Manufacturing

 539991    Gasket, Packing, and Sealing Device
           Manufacturing
 3 3 9992    Musical Instrument Manufacturing
 339993    Fastener, Button,  Needle, and Pin
           Manufacturing
                                 339994    Broom, Brush, and Mop Manufacturing

                                 339995    Burial Casket Manufacturing

                                 339999    All Other Miscellaneous Manufacturing

                                 113310    Logging

                                 111998    All Other Miscellaneous Crop Farming
                                           (Limited to facilities primarily engaged in
                                           reducing maple sap to maple syrup)

                                 211112    Natural Gas Liquid Extraction (limited to
                                           facilities that recover sulfur from natural gas)

                                 212324    Kaolin and Ball Clay Mining (limited to
                                           facilities operating without a mine or quarry
                                           and that are primarily engaged in
                                           beneficiating kaolin and clay)

                                 212325    Clay and Ceramic and Refractory
                                           Minerals Mining (limited to facilities
                                           operating without a mine or quarry and that
                                           are primarily engaged in beneficiating clay
                                           and ceramic and refractory minerals)

                                 212393    Other Chemical and Fertilizer Mineral
                                           Mining (limited to facilities operating
                                           without a mine or quarry that are primarily
                                           engaged in beneficiating chemical or fertilizer
                                           mineral raw materials)

                                 212399    All Other Nonmetallic Mineral Mining
                                           (limited to facilities operating without a mine
                                           or quarry that are primarily engaged in
                                           beneficiating nonmetallic minerals)

                                 488390    Other Support Activities for Water
                                           Transportation (limited to facilities that are
                                           primarily engaged in providing routine repair
                                           and maintenance of ships  and boats from
                                           floating drydocks)

                                 511110    Newspaper Publishers

                                 511120    Periodical Publishers

                                 511130    Book Publishers

                                 511140    Directory and Mailing List Publishers
                                           (except Facilities that are primarily engaged
                                           in furnishing services for direct mail
                                           advertising including address list compilers,
                                           address list publishers, address list publishers
                                           and printing combined, address list
                                           publishing, business directory publishers,
                                           catalog of collections publishers, catalog of
                                           collections publishers and printing combined,
                                           mailing list compilers, directory compilers,
                                           and mailing list compiling services)

                                 511191    Greeting Card Publishers

                                 511199    All Other Publishers
1-18
Toxics Release Inventory Reporting Form and Instructions

-------
                                       Table I. NAICS Codes
 512220    Integrated Record Production/Distribution

 512230    Music Publishers (except facilities primarily
           Engaged n Music copyright authorizing use,
           Music copyright buying and licensing, and
           Music publishers working on their own
           account)

 516110    Internet Publishing and Broadcasting and
           web search portals (limited to facilities
           primarily engaged in Internet newspaper
           publishing, Internet periodical publishing,
           internet book publishing, Miscellaneous
           Internet publishing, Internet greeting card
           publishers except web search portals
                                             541710    Research and Development in the Physical,
                                                       Engineering, and Life Sciences except
                                                       Biotechnology (limited to facilities that are
                                                       primarily engaged in Guided missile and
                                                       space vehicle engine research and
                                                       development, and in Guided missile and
                                                       space vehicle parts (except engines) research
                                                       and development)

                                             811490    Other Personal and Household Goods
                                                       Repair and Maintenance
1.2    NAICS codes that correspond
         to SIC codes other than 20
         through 39:
212      Mining (except Oil and Gas)
2121     Coal Mining

212111    Bituminous Coal and Lignite Surface Mining

212112    B ituminous Coal Underground Mining

212113    Anthracite Mining

2122     Metal Ore Mining

212221    Gold Ore Mining

212222    Silver Ore Mining

212231    Lead Ore and Zinc Ore Mining

212234    Copper Ore and Nickel Ore Mining

212299    All Other Metal Ore Mining
221
Utilities
22111   Electric Power Generation
          (limited to facilities that combust
          coal and/or oil for the purpose of
          generating power for distribution
          in commerce)

221111    Hydroelectric Power Generation

221112    Fossil Fuel Electric Power Generation

221113    Nuclear Electric Power Generation

221119    Other Electric Power Generation

221121    Electric Bulk Power Transmission and
          Control

221122    Electric Power Distribution

221330    Steam and Air Conditioning Supply
          Limited to facilities engaged in providing
          combinations of electric, gas and other
          services, not elsewhere classified (NEC)
          (previously classified under SIC 4939,
          Combination Utility Services Not Elsewhere
          Classified.)

424690    Other Chemical and Allied Products
          Merchant Wholesalers

424710    Petroleum Bulk Stations and Terminals
                      Toxics Release Inventory Reporting Form and Instructions
                                                                                       1-19

-------
                                             Table I. NAICS Codes
425110     Business to Business Electronic Markets
           (limited to facilities previously classified in
           5169, Chemicals and Allied Products, NEC)

425120     Wholesale Trade Agents and Brokers
           (limited to facilities previously classified in
           5169, Chemicals and Allied Products, NEC)

562112     Hazardous Waste Collection (limited to
           facilities primarily engaged in solvent
           recovery services on a contract or fee basis)

562211     Hazardous Waste Treatment and Disposal
           (limited to facilities regulated under the
           Resource Conservation and Recovery Act,
           subtitle C,  42 U.S.C. 6921, et seq.)

562212     Solid Waste Landfill (limited to facilities
           regulated under the Resource Conservation
           and Recovery Act, subtitle C, 42 U.S.C.
           6921, et seq.)

562213     Solid Waste Combustors and Incinerators
           (Limited to facilities regulated under the
           Resource Conservation and Recovery Act,
           subtitle C,  42 U.S.C. 6921 et seq.)

562219     Other Nonhazardous Waste Treatment
           and Disposal (Limited to facilities regulated
           under the Resource Conservation and
           Recovery Act, subtitle C, 42 U.S.C. 6921 et
           seq)

562920     Materials  Recovery Facilities (Limited to
           facilities regulated under the Resource
           Conservation and Recovery Act, subtitle C,
           42 U.S.C. 6921 etseq.)
1-20
Toxics Release Inventory Reporting Form and Instructions

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   Table II.  EPCRA Section 313  Chemical List For Reporting Year 2009
	(including Toxic Chemical Categories)	

Individually listed EPCRA Section 313 chemicals with CAS numbers are arranged alphabetically starting on page II-3. Following the
alphabetical list, the EPCRA Section 313 chemicals are arranged in CAS number order. Covered chemical categories follow.

Certain EPCRA Section 313 chemicals listed in Table II have parenthetic "qualifiers." These qualifiers indicate that these EPCRA
Section 313 chemicals are subject to the section 313 reporting requirements if manufactured, processed, or otherwise used in a specific
form or when a certain activity is performed.  The following chemicals are reportable only if they are manufactured, processed, or
otherwise used in the specific form(s) listed below:
Chemical
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
Ammonia (includes anhydrous ammonia and aqueous ammonia
from water dissociable ammonium salts and other sources; 10
percent of total aqueous ammonia is reportable under this listing)
Asbestos (friable)
Hydrochloric acid (acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle size)
Nitrate compounds (water dissociable; reportable only when in
aqueous solution)
Phosphorus (yellow or white)
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size)
Vanadium (except when contained in an alloy)
Zinc (fume or dust)
CAS Number
7429-90-5
1344-28-1
7664-41-7
1332-21-4
7647-01-0
NA
7723-14-0
7664-93-9
7440-62-2
7440-66-6
Qualifier
Only if it is a fume or dust form.
Only if it is a fibrous form.
Only 10% of aqueous forms. 100% of
anhydrous forms.
Only if it is a friable form.
Only if it is an aerosol form as
defined.
Only if in aqueous solution
Only if it is a yellow or white form.
Only if it is an aerosol form as
defined.
Except if it is contained in an alloy.
Only if it is in a fume or dust form.
The qualifier for the following three chemicals is based on the chemical activity rather than the form of the chemical. These chemicals
are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
Chemical/ Chemical Category
Dioxin and dioxin-like compounds (manufacturing; and the
processing or otherwise use of dioxin and dioxin-like compounds if
the dioxin and dioxin-like compounds are present as contaminants
in a chemical and if they were created during the manufacture of
that chemical.)
Isopropyl alcohol (only persons who manufacture by the strong
acid process are subject, no supplier notification)
Saccharin (only persons who manufacture are subject, no supplier
notification)
CAS
Number
NA
67-63-0
81-07-2
Qualifier
Only if they are manufactured at the
facility; or are processed or otherwise
used when present as contaminants in
a chemical but only if they were
created during the manufacture of that
chemical.
Only if it is being manufactured by the
strong acid process. Facilities that
process or otherwise use isopropyl
alcohol are not covered and should not
file a report.
Only if it is being manufactured.
There are no supplier notification requirements for isopropyl alcohol and saccharin since the processors and users of these chemicals are
not required to report.  Manufacturers of these chemicals do not need to notify their customers that these are reportable EPCRA section
313 chemicals.
                  Toxics Release Inventory Reporting Form and Instructions
II-l

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                               Table II. EPCRA Section 313 Chemical List - RY2009
  Note: Chemicals may be added to or deleted from the list.  The Emergency Planning and Community Right-to-Know Call Center
  will provide up-to-date information on the status of these changes.  See section B.3.c of the instructions for more information on the
  de minimis values listed below.  There are no de minimis levels for PBT chemicals since the de minimis exemption is not available
  for these chemicals (an asterisk appears where a de minimis limit would otherwise appear in Table II). However, for purposes of the
  supplier notification requirement only, such limits are provided in Appendix D.
Chemical Qualifiers
This table  contains the list of individual  EPCRA Section 313
chemicals and categories of chemicals subject to 2009 calendar year
reporting. Some of the EPCRA Section 313 chemicals listed have
parenthetic qualifiers listed next to them. An EPCRA Section 313
chemical that is listed without a qualifier is subject to reporting in all
forms in which it is manufactured, processed, and otherwise used.

Fume or dust  Two of the metals on the list (aluminum and zinc)
contain the qualifier "fume or dust." Fume or dust refers to dry forms
of these metals but does not refer to "wet" forms such as solutions or
slurries. As explained in Section B. 3. a of these instructions, the term
manufacture includes  the  generation of an EPCRA Section 313
chemical as a byproduct or  impurity. In such cases, a facility should
determine if, for example, it generated more than 25,000 pounds of
aluminum fume or dust in the reporting year as a result of its
activities.  If so,  the  facility must report that  it manufactures
"aluminum (fume  or dust)."   Similarly,  there  may be  certain
technologies in which one of these metals is processed in the form of
a fume or dust to make other EPCRA Section 313 chemicals or other
products  for distribution in commerce.   In reporting releases,  the
facility would only  report releases of the fume or dust.

EPA considers dusts to consist of solid particles generated by any
mechanical processing of  materials including crushing, grinding,
rapid impact,  handling, detonation, and decrepitation of organic and
inorganic materials  such as  rock, ore, and metal. Dusts do not tend to
flocculate, except under electrostatic forces.

EPA considers a fume to be  an airborne dispersion consisting of small
solid particles created  by  condensation  from a gaseous state, in
distinction to a gas or vapor. Fumes arise from the heating of solids
such as lead.  The condensation is often accompanied by a chemical
reaction,  such as  oxidation.   Fumes  flocculate  and sometimes
coalesce.

Manufacturing qualifiers. Two of the entries in the EPCRA Section
313 chemical list contain a qualifier relating to manufacture.  For
isopropyl alcohol, the qualifier is "only persons who manufacture by
the  strong acid process are subject, no  supplier notification."  For
saccharin, the qualifier is "only persons who manufacture are subject,
no supplier notification." For isopropyl alcohol, the qualifier means
that only facilities manufacturing isopropyl alcohol by the strong acid
process are  required to report.  In the case of saccharin, only
manufacturers of the EPCRA Section 313 chemical are subject to the
reporting requirements. A  facility that only processes or otherwise
uses either of these EPCRA Section 313 chemicals is not required to
report  for these EPCRA Section 313  chemicals.   In both cases,
supplier notification does not apply because only manufacturers,  not
users, of these two EPCRA Section 313 chemicals must report.
Ammonia  (includes  anhydrous  ammonia and  aqueous
ammonia from water dissociable ammonium salts and other
sources; 10 percent of total aqueous ammonia is reportable
under this listing).   The qualifier for ammonia  means that
anhydrous forms of ammonia are 100% reportable and aqueous
forms are limited to 10% of total aqueous ammonia. Therefore
when determining threshold  and releases  and other waste
management quantities all anhydrous ammonia is included but
only  10%  of  total  aqueous  ammonia is included.    Any
evaporation of  ammonia  from aqueous ammonia solutions is
considered  anhydrous ammonia  and should  be  included  in
threshold  determinations  and  release  and other  waste
management calculations.

Sulfuric acid and Hydrochloric acid (acid aerosols including
mists, vapors,  gas, fog,  and other airborne forms of any
particle size). The qualifier for sulfuric acid and hydrochloric
acid means that the only forms  of these chemicals that are
reportable are airborne forms. Aqueous solutions are not covered
by this listing but any aerosols generated from aqueous  solutions
are covered.

Nitrate compounds (water dissociable; reportable only when
in aqueous solution).  The qualifier for the nitrate compounds
category limits the reporting to nitrate compounds that dissociate
in water, generating nitrate ion. For the purposes  of threshold
determinations the entire weight of the nitrate compound must be
included in all calculations.  For the purposes of reporting
releases and other waste management quantities only the weight
of the nitrate ion should be included in the calculations of these
quantities.

Phosphorus (yellow or white). The listing for phosphorus is
qualified by the term "yellow or white."  This means  that only
manufacturing, processing, or otherwise use of phosphorus in the
yellow or white chemical  form triggers reporting.  Conversely,
manufacturing, processing, or otherwise use of "black" or "red"
phosphorus does not trigger reporting. Supplier notification also
applies only to distribution of yellow or white phosphorus.
Asbestos (friable). The listing for asbestos is qualified by the
term "friable," referring to the physical characteristic of being
able to be crumbled, pulverized, or reducible to a powder with
hand pressure. Only manufacturing, processing, or otherwise use
of asbestos in  the friable form triggers reporting.  Supplier
notification applies only to distribution of mixtures or other trade
name products containing friable asbestos.
Aluminum Oxide (fibrous forms). The listing for aluminum
oxide is qualified by the term "fibrous forms." Fibrous refers to
a man-made form of aluminum oxide that is processed to produce
strands  or  filaments  which can be  cut to various lengths
depending on the application. Only manufacturing, processing,
or otherwise use of aluminum oxide in the fibrous form triggers
reporting. Supplier notification applies  only to distribution of
                             Toxics Release Inventory Reporting Form and Instructions
                                                   II-2

-------
                              Table II. EPCRA Section 313 Chemical List - RY2009
mixtures or other trade name products containing fibrous forms of
aluminum oxide.
         Notes for Sections A and B of following list of
                       TRI chemicals:

        "Color Index" indicated by "C.I."

        * There are no de minimis levels for PBT
        chemicals, except for supplier notification
        purposes (see Appendix D).	
a.
Individually-Listed Toxic Chemicals Arranged
Alphabetically
 CAS Number   Chemical Name
                                     Deminimis
                                       % Limit
 71751-41-2      Abamectin[AvermectinBl]            1.0
 30560-19-1      Acephate                             1.0
                 (Acetylphosphoramidothioic acid O,S-
                 dimethyl ester)
 75-07-0         Acetaldehyde                         0.1
 60-35-5         Acetamide                           0.1
 75-05-8         Acetonitrile                          1.0
 98-86-2         Acetophenone                        1.0
 53-96-3         2-Acetylaminofluorene                0.1
 62476-59-9      Acifluorfen, sodium salt               1.0
                 [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
                 2-nitrobenzoic acid, sodium salt]
 107-02-8        Acrolein                             1.0
 79-06-1         Acrylamide                          0.1
 79-10-7         Acrylic acid                          1.0
 107-13-1        Acrylonitrile                         0.1
 15972-60-8      Alachlor                             1.0
 116-06-3        Aldicarb                             1.0
 309-00-2        Aldrin                                 *
                 [l,4:5,8-Dimethanonaphthalene,
                 l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
                 hexahydro-(l.alpha.,4.alpha.,4a.beta.,
                 5.alpha.,8.alpha.,8a.beta.)-]
 28057-48-9      d-trans-Allethrin                      1.0
                 [d-trans-Chrysanthemic acid of d-allethrone]
 107-18-6        Allyl alcohol                         1.0
 107-11-9        Allylamine                           1.0
 107-05-1        Allyl chloride                         1.0
 7429-90-5       Aluminum (fume or dust)              1.0
 20859-73-8      Aluminum phosphide                  1.0
 1344-28-1       Aluminum oxide (fibrous forms)        1.0
 834-12-8        Ametryn                             1.0
                 (N-Ethyl-N=-( 1 -methylethyl)-6-
                 (methylthio)-l,3,5,-triazine-2,4-diamine)
 117-79-3        2-Aminoanthraquinone                0.1
 60-09-3         4-Aminoazobenzene                  0.1
 92-67-1         4-Aminobiphenyl                     0.1
 82-28-0         l-Amino-2-methylanthraquinone        0.1
 33089-61-1      Amitraz                              1.0
 61-82-5         Amitrole                             0.1
 7664-41-7       Ammonia                            1.0
                 (includes anhydrous ammonia and aqueous
                 ammonia from water dissociable ammonium
                                                       CAS Number   Chemical Name
                                              Deminimis
                                                % Limit
                salts and other sources; 10 percent of total
                aqueous ammonia is reportable under this
                listing)
101-05-3        Anilazine                             1.0
                [4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
                triazin-2-amine]
62-53-3         Aniline                               1.0
90-04-0         o-Anisidine                           0.1
104-94-9        p-Anisidine                           1.0
134-29-2        o-Anisidine hydrochloride              0.1
120-12-7        Anthracene                           1.0
7440-36-0       Antimony                            1.0
7440-38-2       Arsenic                               0.1
1332-21-4       Asbestos (friable)                     0.1
1912-24-9       Atrazine                             1.0
                (6-Chloro-N-ethyl-N=-(l-methylethyl)-
                1,3,5-triazine-2,4-diamine)
7440-39-3       Barium                               1.0
22781-23-3      Bendiocarb                           1.0
                [2,2-Dimethyl-l,3-benzodioxol-4-ol
                methylcarbamate]
1861-40-1       Benfluralin                           1.0
                (N-Butyl-N-ethyl-2,6-dinitro-4-
                (trifluoromethyl)benzenamine)
17804-35-2      Benomyl                             1.0
98-87-3         Benzal chloride                       1.0
55-21-0         Benzamide                           1.0
71-43-2         Benzene                             0.1
92-87-5         Benzidine                            0.1
98-07-7         Benzoic trichloride                    0.1
                (Benzotrichloride)
191-24-2        Benzo(g,h,i)perylene                    *
98-88-4         Benzoyl chloride                      1.0
94-36-0         Benzoyl peroxide                     1.0
100-44-7        Benzyl chloride                       1.0
7440-41-7       Beryllium                            0.1
82657-04-3      Bifenthrin                            1.0
92-52-4         Biphenyl                             1.0
111-91-1        Bis(2-chloroethoxy) methane           1.0
111-44-4        Bis(2-chloroethyl) ether                1.0
542-88-1        Bis(chloromethyl) ether                0.1
108-60-1        Bis(2-chloro-l-methylethyl)ether        1.0
56-35-9         Bis(tributyltin) oxide                  1.0
10294-34-5      Boron trichloride                      1.0
7637-07-2       Boron trifluoride                      1.0
314-40-9        Bromacil                             1.0
                (5-Bromo-6-methyl-3-(l-methylpropyl)-
                2,4(lH,3H)-pyrimidinedione)
53404-19-6      Bromacil, lithium salt                  1.0
                [2,4(lH,3H)-Pyrimidinedione,5-bromo-6-
                methyl-3-(l-methylpropyl), lithium salt]
7726-95-6       Bromine                             1.0

35691-65-7      l-Bromo-l-(bromomethyl)-             1.0
                1,3 -propanedicarbonitrile
353-59-3        Bromochlorodifluoromethane           1.0
                (Halonl211)
75-25-2	Bromoform (Tribromomethane)	1.0
                           Toxics Release Inventory Reporting Form and Instructions
                                                                                                       II-3

-------
                             Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number   Chemical Name
Deminimis
  % Limit
74-83-9         Bromomethane                        1.0
                (Methyl bromide)
75-63-8         Bromotrifluoromethane                1.0
                (Halon 1301)
1689-84-5       Bromoxynil                          1.0
                (3,5-Dibromo-4-hydroxybenzonitrile)
1689-99-2       Bromoxynil octanoate                 1.0
                (Octanoic acid, 2,6-dibromo-4-
                cyanophenylester)
357-57-3        Bracine                              1.0
106-99-0        1,3-Butadiene                         0.1
141-32-2        Butyl acrylate                         1.0
71-36-3         n-Butyl alcohol                        1.0
78-92-2         sec-Butyl alcohol                     1.0
75-65-0         tert-Butyl alcohol                     1.0
106-88-7        1,2-Butylene oxide                    0.1
123-72-8        Butyraldehyde                        1.0
7440-43-9       Cadmium                            0.1
156-62-7        Calcium cyanamide                    1.0
133-06-2        Captan                               1.0
                [lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-
                tetrahydro-2-[(trichloromethyl)thio]-]
63-25-2         Carbaryl [1-Naphthalenol,              1.0
                methylcarbamate]
1563-66-2       Carbofuran                           1.0
75-15-0         Carbon disulfide                      1.0
56-23-5         Carbon tetrachloride                   0.1
463-58-1        Carbonyl sulfide                      1.0
5234-68-4       Carboxin                             1.0
                (5,6-Dihydro-2-methyl-N-
                phenyl-1,4-oxathiin-3 -carboxamide)
120-80-9        Catechol                             0.1
2439-01-2       Chinomethionat                       1.0
                [6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
                one]
133-90-4        Chloramben                          1.0
                [Benzoic acid, 3-amino-2,5-dichloro-]
57-74-9         Chlordane                              *
                [4,7-Methanoindan, 1,2,4,5,6,7,8,8-
                octachloro-2,3,3a,4,7,7a-hexahydro-]
115-28-6        Chlorendic acid                       0.1
90982-32-4      Chlorimuron ethyl                     1.0
                [Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-
                2-y l)amino] carbony 1] amino] sulfonyl]
                benzoate]
7782-50-5       Chlorine                              .0
10049-04-4      Chlorine dioxide                       .0
79-11-8         Chloroacetic acid                      .0
532-27-4        2-Chloroacetophenone                  .0
4080-31-3       l-(3-Chloroallyl)-3,5,7-triaza-           .0
                1-azoniaadamantane chloride
106-47-8        p-Chloroaniline                        0.1
108-90-7        Chlorobenzene                        1.0
510-15-6        Chlorobenzilate                       1.0
                [Benzeneacetic acid, 4-chloro-.alpha.- (4-
                chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
75-68-3         l-Chloro-l,l-difluoroethane            1.0
                (HCFC-142b)
75-45-6         Chlorodifluoromethane                1.0
CAS Number   Chemical Name
Deminimis
  % Limit
                                  (HCFC-22)
                  75-00-3          Chloroethane (Ethyl chloride)           1.0
                  67-66-3          Chloroform                           0.1
                  74-87-3          Chloromethane (Methyl chloride)        1.0
                  107-30-2        Chloromethyl methyl ether             0.1
                  563-47-3        3-Chloro-2-methyl-l-propene           0.1
                  104-12-1        p-Chlorophenyl isocyanate             1.0
                  76-06-2          Chloropicrin                          1.0
                  126-99-8        Chloroprene                          0.1
                  542-76-7        3-Chloropropionitrile                   1.0
                  63938-10-3      Chlorotetrafluoroethane                1.0
                  354-25-6        1-Chloro-l, 1,2,2-                      1.0
                                  tetrafluoroethane (HCFC-124a)
                  2837-89-0       2-Chloro-l,l,l,2-                      1.0
                                  tetrafluoroethane (HCFC-124)
                  1897-45-6       Chlorothalonil                         0.1
                                  [1,3-Benzenedicarbonitrile, 2,4,5,6-
                                  tetrachloro-]
                  95-69-2          p-Chloro-o-toluidine                   0.1
                  75-88-7          2-Chloro-l,l,l-                       1.0
                                  trifluoroethane  (HCFC-133a)
                  75-72-9          Chlorotrifluoromethane (CFC-13)       1.0
                  460-35-5        3-Chloro-l,l,l-                       1.0
                                  trifluoropropane (HCFC-253fb)
                  5598-13-0       Chlorpyrifos methyl                   1.0
                                  [O,O-Dimethyl-O-(3,5,6-trichloro-2-
                                  pyridyl)phosphorothioate]
                  64902-72-3      Chlorsulfuron                         1.0
                                  [2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
                                  triazin-2-yl)amino] carbony 1]
                                  benzenesulfonamide]
                  7440-47-3       Chromium                            1.0
                  4680-78-8       C.I. Acid Green 3                      1.0
                  6459-94-5       C.I. Acid Red 114                      0.1
                  569-64-2        C.I. Basic Green 4                     1.0
                  989-38-8        C.I. Basic Red  1                       1.0
                  1937-37-7       C.I. Direct Black 38                   0.1
                  2602-46-2       C.I. Direct Blue 6                      0.1
                  28407-37-6      C.I. Direct Blue 218                   1.0
                  16071-86-6      C.I. Direct Brown 95                   0.1
                  2832-40-8       C.I. Disperse Yellow 3                 1.0
                  3761-53-3       C.I. Food Red 5                       0.1
                  81-88-9          C.I. Food Red 15                      1.0
                  3118-97-6       C.I. Solvent Orange 7                  1.0
                  97-56-3          C.I. Solvent Yellow 3                   0.1
                  842-07-9        C.I. Solvent Yellow 14                 1.0
                  492-80-8        C.I. Solvent Yellow 34                 0.1
                                  (Auramine)
                  128-66-5        C.I. Vat Yellow 4                      1.0
                  7440-48-4       Cobalt                               0.1
                  7440-50-8       Copper                               1.0
                  8001-58-9       Creosote                              0.1
                  120-71-8        p-Cresidine                           0.1
                  108-39-4        m-Cresol                             1.0
                  95-48-7          o-Cresol                              1.0
                  106-44-5        p-Cresol                              1.0
                  1319-77-3       Cresol (mixed isomers)                1.0
                  4170-30-3       Crotonaldehyde                       1.0
                  98-82-8          Cumene                              1.0
                          Toxics Release Inventory Reporting Form and Instructions
                                                                 II-4

-------
  Table II. EPCRA Section 313 Chemical List - RY2009

CAS Number
80-15-9
135-20-6


21725-46-2
1134-23-2
110-82-7
108-93-0
68359-37-5




68085-85-8



94-75-7

533-74-4


53404-60-7


94-82-6
1929-73-3
94-80-4
2971-38-2
1163-19-5
13684-56-5
1928-43-4
53404-37-8

2303-16-4


615-05-4
39156-41-7
101-80-4
95-80-7
25376-45-8
333-41-5
334-88-3
132-64-9
96-12-8


106-93-4

124-73-2

84-74-2
1918-00-9

99-30-9

95-50-1
541-73-1
Deminimis
Chemical Name % Limit
Cumene hydroperoxide 1.0
Cupferron 0.1
[Benzeneamine, N-hydroxy-
N-nitroso, ammonium salt]
Cyanazine .0
Cycloate .0
Cyclohexane .0
Cyclohexanol .0
Cyfluthrin .0
[3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid,
cyano(4-fluoro-3 -phenoxyphenyl) methyl
ester]
Cyhalothrin 1.0
[3 -(2-Chloro-3,3 ,3 -trifluoro- 1 -propenyl)-
2,2-dimethylcyclopropane-carboxylic acid
cyano(3-phenoxyphenyl)methyl ester]
2,4-D 0.1
[Acetic acid, (2,4-dichlorophenoxy)-]
Dazomet 1.0
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
Dazomet, sodium salt 1.0
[Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione, ion(l-), sodium]
2,4-DB 1.0
2,4-D butoxyethyl ester 0. 1
2,4-D butyl ester 0.1
2,4-D chlorocrotyl ester 0. 1
Decabromodipheny 1 oxide 1 . 0
De smedipham 1 . 0
2,4-D 2-ethylhexyl ester 0. 1
2,4-D 2-ethyl-4- 0.1
methylpentyl ester
Diallate 1.0
[Carbamothioic acid, bis(l-methylethyl)-S-
(2,3-dichloro-2-propenyl) ester]
2,4-Diaminoanisole 0.
2,4-Diaminoanisole sulfate 0.
4,4'-Diaminodiphenyl ether 0.
2,4-Diaminotoluene 0.
Diaminotoluene (mixed isomers) 0.
Diazinon 1.0
Diazomethane 1.0
Dibenzofuran 1.0
l,2-Dibromo-3- 0.1
chloropropane (DBCP)

1,2-Dibromoethane 0.1
(Ethylene dibromide)
Dibromotetrafluoroethane 1 . 0
(Halon 2402)
Dibutyl phthalate 1.0
Dicamba 1.0
(3 ,6-Dichloro-2-methoxybenzoic acid)
Dichloran 1.0
[2,6-Dichloro-4-nitroaniline]
1,2-Dichlorobenzene 1.0
1,3-Dichlorobenzene 1.0





























































Deminimis
CAS Number
106-46-7
25321-22-6
91-94-1
612-83-9

64969-34-2
75-27-4
764-41-0
110-57-6
1649-08-7

75-71-8
107-06-2

540-59-0
1717-00-6

75-43-4
75-09-2

127564-92-5
13474-88-9

111512-56-2

422-44-6

431-86-7

507-55-1

136013-79-1

128903-21-9

422-48-0

422-56-0

97-23-4

120-83-2
78-87-5
10061-02-6
78-88-6
542-75-6
76-14-2

34077-87-7
90454-18-5
812-04-4

354-23-4

306-83-2

62-73-7


Chemical Name %
1 ,4-Dichlorobenzene
Dichlorobenzene (mixed isomers)
3 ,3 '-Dichlorobenzidine
3 ,3 '-Dichlorobenzidine
dihydrochloride
3, 3 '-Dichlorobenzidine sulfate
Dichlorobromomethane
1 ,4-Dichloro-2-butene
trans- 1 ,4-Dichloro-2-butene
l,2-Dichloro-l,l-
difluoroethane (HCFC-132b)
Dichlorodifluoromethane (CFC-12)
1,2-Dichloroethane (Ethylene
dichloride)
1 ,2-Dichloroethylene
1 , 1 -Dichloro- 1 -fluoroethane
(HCFC-141b)
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene
chloride)
Dichloropentafluoropropane
l,l-Dichloro-l,2,2,3,3-
pentafluoropropane (HCFC-225cc)
l,l-Dichloro-l,2,3,3,3-
pentafluoropropane (HCFC-225eb)
1,2-Dichloro-l, 1,2,3,3-
pentafluoropropane (HCFC-225bb)
1,2-Dichloro-l, 1,3,3,3-
pentafluoropropane (HCFC-225da)
1,3 -Dichloro- 1,1, 2,2,3-
pentafluoropropane (HCFC-225cb)
1,3 -Dichloro- 1, 1,2,3,3-
pentafluoropropane (HCFC-225ea)
2,2-Dichloro-l, 1,1,3,3-
pentafluoropropane (HCFC-225aa)
2,3 -Dichloro- 1, 1,1,2,3-
pentafluoropropane (HCFC-225ba)
3, 3 -Dichloro- 1, 1,1,2,2-
pentafluoropropane (HCFC-225ca)
Dichlorophene
[2,2'-Methylenebis(4-chlorophenol)]
2,4-Dichlorophenol
1 ,2-Dichloropropane
trans- 1 ,3 -Dichloropropene
2,3 -Dichloropropene
1 ,3 -Dichloropropylene
Dichlorotetrafluoroethane
(CFC-114)
Dichlorotrifluoroethane
Dichloro- 1 , 1 ,2-trifluoroethane
1,1 -Dichloro- 1,2,2-
trifluoroethane (HCFC-123b)
1,2-Dichloro-l, 1,2-
trifluoroethane (HCFC-123a)
2,2-Dichloro-l, 1,1-
trifluoroethane (HCFC-123)
Dichlorvos
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Limit
0.
0.
0.
0.

0.
0.
1.0
1.0
1.0

1.0
0.1

1.0
1.0

1.0
0.1

1.0
1.0

1.0

1.0

1.0

1.0

1.0

1.0

1.0

1.0

1.0

1.0
1.0
0.1
1.0
0.1
1.0

1.0
1.0
1.0

1.0

1.0

0.1


Toxics Release Inventory Reporting Form and Instructions
II-5

-------
                              Table II. EPCRA Section 313 Chemical List - RY2009
 CAS Number   Chemical Name
Deminimis
  % Limit
 51338-27-3      Diclofop methyl                       1.0
                 [2-[4-(2,4-Dichlorophenoxy)phenoxy]
                 propanoic acid, methyl ester]
 115-32-2        Dicofol                              1.0
                 [Benzenemethanol, 4-chloro-
 77-73-6         Dicyclopentadiene                     1.0
 1464-53-5       Diepoxybutane                        0.1
 111-42-2        Diethanolamine                       1.0
 38727-55-8      Diethatyl ethyl                        1.0
 117-81-7        Di(2-ethylhexyl) phthalate (DEHP)      0.1
 64-67-5         Diethyl sulfate                        0.1
 35367-38-5      Diflubenzuron                        1.0
 101-90-6        Diglycidyl resorcinol ether             0.1
 94-58-6         Dihydrosafrole                        0.1
 55290-64-7      Dimethipin                           1.0
                 [2,3-Dihydro-5,6-dimethyl-l,4-dithiin
                 1,1,4,4-tetraoxide]
 60-51-5         Dimethoate                           1.0
 119-90-4        3,3'-Dimethoxybenzidine               0.1
 20325-40-0      3,3'-Dimethoxybenzidine               0.1
                 dihydrochloride (o-Dianisidine
                 dihydrochloride)
 111984-09-9     3,3'-Dimethoxybenzidine               0.1
                 hydrochloride (o-Dianisidine hydrochloride)
 124-40-3        Dimethylamine                        1.0
 2300-66-5       Dimethylamine dicamba               1.0
 60-11-7         4-Dimethylaminoazobenzene           0.1
 121-69-7        N,N-Dimethylaniline                  1.0
 119-93-7        3,3'-Dimethylbenzidine(o-Tolidine)     0.1
 612-82-8        3,3'-Dimethylbenzidine                0.1
                 dihydrochloride (o-Tolidine
                 dihydrochloride)
 41766-75-0      3,3'-Dimethylbenzidine                0.1
                 dihydrofluoride (o-Tolidine dihydrofluoride)
 79-44-7         Dimethylcarbamyl chloride             0.1
 2524-03-0       Dimethyl                             1.0
                 chlorothiophosphate
 68-12-2         N,N-Dimethylformamide               1.0
 57-14-7         U-Dimethylhydrazine                0.1
 105-67-9        2,4-Dimethyrphenol                   1.0
 131-11-3        Dimethyl phthalate                    1.0
 77-78-1         Dimethyl sulfate                       0.1
 99-65-0         m-Dinitrobenzene                     1.0
 528-29-0        o-Dinitrobenzene                      1.0
 100-25-4        p-Dinitrobenzene                      1.0
 88-85-7         Dinitrobutyl phenol (Dinoseb)          1.0
 534-52-1        4,6-Dinitro-o-cresol                   1.0
 51-28-5         2,4-Dinitrophenol                     1.0
 121-14-2        2,4-Dinitrotoluene                     0.1
 606-20-2        2,6-Dinitrotoluene                     0.1
 25321-14-6      Dinitrotoluene (mixed isomers)         1.0
 39300-45-3      Dinocap                              1.0
 123-91-1        1,4-Dioxane                          0.1
 957-51-7        Diphenamid                          1.0
 122-39-4        Diphenylamine                        1.0
 122-66-7        1,2-Diphenylhydrazine                 0.1
                 (Hydrazobenzene)
 2164-07-0       Dipotassium endothall                 1.0
	[7-Oxabicyclo(2.2.1)heptane-2,3-	
CAS Number   Chemical Name
Deminimis
  % Limit
                                  dicarboxylic acid, dipotassium salt]
                  136-45-8        Dipropyl isocinchomeronate            1.0
                  138-93-2        Disodium                             1.0
                                  cyanodithioimidocarbonate
                  94-11-1         2,4-D isopropyl ester                  0.1
                  541-53-7        2,4-Dithiobiuret                       1.0
                  330-54-1        Diuron                               1.0
                  2439-10-3       Dodine [Dodecylguanidine             1.0
                                  monoacetate]
                  120-36-5        2,4-DP                               0.1
                  1320-18-9       2,4-D propylene glycol                 0.1
                                  butyl ether ester
                  2702-72-9       2,4-D sodium salt                     0.1
                  106-89-8        Epichlorohydrin                       0.1
                  13194-48-4      Ethoprop                             1.0
                                  [Phosphorodithioic acid O-ethyl S,S-
                                  dipropyl ester]
                  110-80-5        2-Ethoxyethanol                       1.0
                  140-88-5        Ethyl acrylate                         0.1
                  100-41-4        Ethylbenzene                          0.1
                  541-41-3        Ethyl chloroformate                    1.0
                  759-94-4        Ethyl dipropylthiocarbamate            1.0
                                  (EPTC)
                  74-85-1         Ethylene                             1.0
                  107-21-1        Ethylene glycol                       1.0
                  151-56-4        Ethyleneimine (Aziridine)              0.1
                  75-21-8         Ethylene oxide                        0.1
                  96-45-7         Ethylene thiourea                     0.1
                  75-34-3         Ethylidene dichloride                  1.0
                  52-85-7         Famphur                             1.0
                  60168-88-9      Fenarimol                            1.0
                                  [.alpha.-(2-Chlorophenyl)-.alpha.-(4-
                                  chlorophenyl)-5-pyrimidinemethanol]
                  13356-08-6      Fenbutatin oxide                       1.0
                                  (Hexakis(2-methyl-2-phenylpropyl)
                                  distannoxane)
                  66441-23-4      Fenoxaprop ethyl                     1.0
                                  [2-(4-((6-Chloro-2-
                                  benzoxazolylen)oxy)phenoxy)propanoic
                                  acid, ethyl ester]
                  72490-01-8      Fenoxycarb                           1.0
                                  [[2-(4-Phenoxyphenoxy)ethyl]carbamic acid
                                  ethyl ester]
                  39515-41-8      Fenpropathrin                         1.0
                                  [2,2,3,3 -Tetramethylcyclopropane
                                  carboxylic acid cyano(3-
                                  phenoxyphenyl)methyl ester]
                  55-38-9         Fenthion                             1.0
                                  [O,O-Dimethyl O-[3-methyl-4-
                                  (methylthio)phenyl] ester, phosphorothioic
                                  acid]
                  51630-58-1      Fenvalerate                           1.0
                                  [4-Chloro-alpha-(l-methylethyl)
                                  benzeneacetic acid cyano (3-
                                  phenoxyphenyl) methyl ester]
                  14484-64-1      Ferbam                               1.0
                 	|Tris(dimethylcarbamodithioato- S,S')iron]
                           Toxics Release Inventory Reporting Form and Instructions
                                                                  II-6

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  Table II. EPCRA Section 313 Chemical List - RY2009

CAS Number
69806-50-4



2164-17-2


7782-41-4
51-21-8
69409-94-5



133-07-3
72178-02-0


50-00-0
64-18-6
76-13-1

76-44-8


118-74-1
87-68-3
319-84-6
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
110-54-3
51235-04-2
67485-29-4




302-01-2
10034-93-2
7647-01-0



74-90-8
7664-39-3
123-31-9
35554.44-0


55406-53-6

13463-40-6
78-84-2
465-73-6
25311-71-1


Deminimis
Chemical Name % Limit
Fluazif op butyl 1.0
[2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]phenoxy]propanoic acid,
butyl ester]
Fluometuron 1.0
[Urea, N,N-dimethyl-N=-[3-
(trifluoromethy l)pheny 1] -]
Fluorine 1.0
Fluorouracil (5 -Fluorouracil) 1 . 0
Fluvalinate 1.0
[N-[2-Chloro-4-(trifluoromethyl)phenyl]-
DL-valine(+)-cyano(3 -
phenoxyphenyl)methyl ester]
Folpet 1.0
Fomesafen 1.0
[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
N-methylsulfonyl-2-nitrobenzamide]
Formaldehyde 0.1
Formic acid 1.0
FreonllS 1.0
[Ethane, 1 , 1 ,2-trichloro- 1 ,2,2,-trifluoro-]
Heptachlor *
[l,4,5,6,7,8,8-Heptachloro-3a, 4,7,7a-
tetrahydro-4,7-methano-lH-indene]
Hexachlorobenzene *
Hexachloro- 1,3 -butadiene 1.0
alpha-Hexachlorocyclohexane 0.1
Hexachlorocy clopentadiene 1 . 0
Hexachloroethane 0.1
Hexachloronaphthalene .0
Hexachlorophene .0
Hexamethylphosphoramide 0.1
n-Hexane .0
Hexazinone .0
Hydramethylnon .0
[Tetrahydro-5,5-dimethyl-2(lH)-
py rimidinone [3 - [4-(trifluoromethy l)pheny 1] -
l-[2-[4-(trifluoromethyl)phenyl]ethenyl]-2-
propeny lidene] hy drazone]
Hydrazine 0.1
Hydrazine sulfate 0.1
Hydrochloric acid 1.0
(acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle
size)
Hydrogen cyanide 1 . 0
Hydrogen fluoride 1 . 0
Hydroquinone 1.0
Imazalil 1.0
[l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl] - IH-imidazole]
3-Iodo-2-propynyl 1.0
butylcarbamate
Iron pentacarbony 1 1 . 0
Isobuty raldehy de 1 . 0
Isodrin *
Isofenphos[2-[[Ethoxyl[(l- 1.0
methylethyl)amino]phosphinothioyl]oxy]































































CAS Number

67-63-0



80-05-7
120-58-1
77501-63-4



7439-92-1



58-89-9



330-55-2
554-13-2
121-75-5
108-31-6
109-77-3
12427-38-2


7439-96-5
93-65-2
149-30-4
7439.97-6
150-50-5
126-98-7
137-42-8

67-56-1
20354-26-1


2032-65-7
94-74-6


3653-48-3


72-43-5


109-86-4
96-33-3
1634-04-4
79-22-1
101-14-4

101-61-1

74-95-3
101-77-9
Deminimis
Chemical Name % Limit
benzoic acid 1-methylethyl ester]
Isopropyl alcohol 1.0
(only persons who manufacture by the
strong acid process are subject, no supplier
notification)
4,4'-Isopropylidenediphenol 1.0
Isosafrole 1.0
Lactofen 1.0
[Benzoic acid, 5-[2-Chloro-4-
(trifluoromethyl)phenoxy]-2-nitro-, 2-
ethoxy-l-methyl-2-oxoethyl ester]
Lead *
(when lead is contained in stainless steel,
brass or bronze alloys the de minimis level is
0.1)
Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,
6.beta.)-]
Linuron 1.0
Lithium carbonate 1.0
Malathion 1.0
Maleic anhydride 1.0
Malononitrile 1.0
Maneb 1.0
[Carbamodithioic acid, 1,2-ethanediylbis-,
manganese complex]
Manganese 1.0
Mecoprop 0.1
2-Mercaptobenzothiazole (MET) 1.0
Mercury *
Merphos 1.0
Methacrylonitrile 1.0
Metham sodium (Sodium 1.0
methyldithiocarbamate)
Methanol 1.0
Methazole 1.0
[2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3 , 5 -dione]
Methiocarb 1.0
Methoxone 0.1
((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
Methoxone sodium salt 0. 1
((4-Chloro-2-methylphenoxy) acetate
sodium salt)
Methoxychlor *
[Benzene, 1, 1 '-(2,2,2-
trichloroethylidene)bis[4-methoxy-]
2-Methoxyethanol 1.0
Methyl acrylate 1.0
Methyl tert-butyl ether 1 .0
Methyl chlorocarbonate 1.0
4,4'-Methylenebis(2-chloroaniline) 0. 1
(MBOCA)
4,4'-Methylenebis(N,N-dimethyl) 0. 1
benzenamine
Methylene bromide 1.0
4,4'-Methylenedianiline 0.1
Toxics Release Inventory Reporting Form and Instructions
II-7

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                             Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number   Chemical Name
Deminimis
  % Limit
60-34-4         Methyl hydrazine                      .0
74-88-4         Methyl iodide                          .0
108-10-1        Methyl isobutyl ketone                  .0
624-83-9        Methyl isocyanate                      .0
556-61-6        Methyl isothiocyanate                  .0
                [Isothiocyanatomethane]
75-86-5         2-Methyllactonitrile                    .0
80-62-6         Methyl methacrylate                    .0
924-42-5        N-Methylolacrylamide                  .0
298-00-0        Methyl parathion                      .0
109-06-8        2-Methylpyridine                      .0
872-50-4        N-Methyl-2-pyrrolidone                .0
9006-42-2       Metiram                              .0
21087-64-9      Metribuzin                            .0
7786-34-7       Mevinphos                            .0
90-94-8         Michler's ketone                      0.1
2212-67-1       Molinate                             1.0
                (IH-Azepine-l-carbothioic acid, hexahydro-
                , S-ethyl ester)
1313-27-5       Molybdenum trioxide                  1.0
76-15-3         Monochloropentafluoroethane          1.0
                (CFC-115)
150-68-5        Monuron                             1.0
505-60-2        Mustard gas                          0.1
                [Ethane, l,l'-thiobis[2-chloro-]
88671-89-0      Myclobutanil                         1.0
                [.alpha.-Butyl-.alpha.-(4-chlorophenyl)-lH-
                1,2,4-triazole-1 -propanenitrile]
142-59-6        Nabam                               1.0
300-76-5        Naled                                1.0
91-20-3         Naphthalene                          0.1
134-32-7        alpha-Naphthylamine                  0.1
91-59-8         beta-Naphthylamine                   0.1
7440-02-0       Nickel                               0.1
1929-82-4       Nitrapyrin                            1.0
                (2-Chloro-6-(trichloromethyl)pyridine)
7697-37-2       Nitric acid                            1.0
139-13-9        Nitrilotriacetic acid                    0.1
100-01-6        p-Nitroaniline                         1.0
99-59-2         5-Nitro-o-anisidine                    1.0
98-95-3         Nitrobenzene                         0.1
92-93-3         4-Nitrobiphenyl                       0.1
1836-75-5       Nitrofen                             0.1
                [Benzene, 2,4-dichloro-l-(4-nitrophenoxy)-]
51-75-2         Nitrogen mustard                     0.1
                [2-Chloro-N-(2-chloroethyl)-N-
                methylethanamine]
55-63-0         Nitroglycerin                         1.0
88-75-5         2-Nitrophenol                         1.0
100-02-7        4-Nitrophenol                         1.0
79-46-9         2-Nitropropane                        0.1
924-16-3        N-Nitrosodi-n-butylamine              0.1
55-18-5         N-Nitrosodiethylamine                 0.1
62-75-9         N-Nitrosodimethylamine               0.1
86-30-6         N-Nitrosodiphenylamine               1.0
156-10-5        p-Nitrosodiphenylamine               1.0
621-64-7        N-Nitrosodi-n-propylamine            0.1
759-73-9        N-Nitroso-N-ethylurea                 0.1
684-93-5        N-Nitroso-N-methylurea               0.1
CAS Number   Chemical Name
Deminimis
  % Limit
                                                                       1.0
                                                                         *
                                                                       1.0
                                                                       1.0
                                                                       1.0
                                                                       1.0
4549-40-0       N-Nitrosomethylvinylamine            0.1
59-89-2         N-Nitrosomorpholine                  0.1
16543-55-8      N-Nitrosonornicotine                  0.1
100-75-4        N-Nitrosopiperidine                   0.1
99-55-8         5-Nitro-o-toluidine                    1.0
27314-13-2      Norflurazon                          1.0
                [4-Chloro-5-(methylamino)-2-[3-
                (trifluoromethyl)phenyl] -3 (2H)-
                pyridazinone]
2234-13-1       Octachloronaphthalene
29082-74-4      Octachlorostyrene
19044-88-3      Oryzalin
                [4-(Dipropylamino)-3,5-dinitrobenzene
                sulfonamide]
20816-12-0      Osmium tetroxide
301-12-2        Oxydemeton methyl
                [S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
                ester phosphorothioic acid]
19666-30-9      Oxydiazon
                [3-[2,4-Dichloro-5-(l-
                methylethoxy)phenyl]- 5-(l,l-
                dimethylethyl)-l,3,4-oxadiazol-2(3H)-one]
42874-03-3      Oxyfluorfen                          1.0
10028-15-6      Ozone                               1.0
123-63-7        Paraldehyde                          1.0
1910-42-5       Paraquat dichloride                    1.0
56-38-2         Parathion                             1.0
                [Phosphorothioic acid, O,O-diethyl-O-(4-
                nitrophenyl)ester]
1114-71-2       Pebulate                             1.0
                [Butylethylcarbamothioic acid S-propyl
                ester]
40487-42-1      Pendimethalin                          *
                [N-(l-Ethylpropyl)-3,4-dimethyl-2,6-
                dinitrobenzenamine]
608-93-5        Pentachlorobenzene                     *
76-01-7         Pentachloroethane                     1.0
87-86-5         Pentachlorophenol (PCP)              0.1
57-33-0         Pentobarbital sodium                  1.0
79-21-0         Peracetic acid                         1.0
594-42-3        Perchloromethyl mercaptan            1.0
52645-53-1      Permethrin                           1.0
                [3-(2,2-Dichloroethenyl)-2,2-
                dimethylcyclopropanecarboxylic acid, (3-
                phenoxyphenyl) methyl ester]
85-01-8         Phenanthrene                         1.0
108-95-2        Phenol                               1.0
26002-80-2      Phenothrin                           1.0
                [2,2-Dimethyl-3 -(2-methyl-l -
                propenyl)cyclopropanecarboxylic acid (3-
                phenoxyphenyl)methyl ester]
95-54-5         1,2-Phenylenediamine                 1.0
108-45-2        1,3-Phenylenediamine                 1.0
106-50-3        p-Phenylenediamine                   1.0
615-28-1        1,2-Phenylenediamine dihydro-         1.0
                chloride
624-18-0        1,4-Phenylenediamine dihydro-         1.0
                chloride
90-43-7	2-Phenylphenol	1.0
                          Toxics Release Inventory Reporting Form and Instructions
                                                                  II-8

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                              Table II. EPCRA Section 313 Chemical List - RY2009
 CAS Number   Chemical Name
Deminimis
  % Limit
 57-41-0         Phenytoin                            0.1
 75-44-5         Phosgene                             1.0
 7803-51-2       Phosphine                            1.0
 7723-14-0       Phosphorus (yellow or white)           1.0
 85-44-9         Phthalic anhydride                     1.0
 1918-02-1       Picloram                             1.0
 88-89-1         Picric acid                            1.0
 51-03-6         Piperonyl butoxide                     1.0
 29232-93-7      Pirimiphos methyl                     1.0
                 [O-(2-(Diethylamino)-6-methyl-4-
                 pyrimidinyl)-O,O-
                 dimethylphosphorothioate]
 1336-36-3       Polychlorinated biphenyls                *
                 (PCBs)
 7758-01-2       Potassium bromate                     0.1
 128-03-0        Potassium dimethyldithio-              1.0
                 carbamate
 137-41-7        Potassium N-methyldithio-             1.0
                 carbamate
 41198-08-7      Profenofos                            1.0
                 [O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
                 propyl phosphorothioate]
 7287-19-6       Prometryn                            1.0
                 [N,N' -Bis( 1 -methylethyl)-6-methylthio-
                 l,3,5-triazine-2,4-diamine]
 23950-58-5      Pronamide                            1.0
 1918-16-7       Propachlor                            1.0
                 [2-Chloro-N-( 1 -methylethyl)-N-
                 phenylacetamide]
 1120-71-4       Propane sultone                       0.1
 709-98-8        Propanil                              1.0
                 [N-(3,4-Dichlorophenyl)propanamide]
 2312-35-8       Propargite                            1.0
 107-19-7        Propargyl alcohol                      1.0
 31218-83-4      Propetamphos                         1.0
                 [3-[(Ethylamino)methoxyphosphinothioyl]
                 oxy]-2-butenoic acid, 1-methylethyl ester]
 60207-90-1      Propiconazole                         1.0
                 [l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
                 dioxolan-2-yl]-methyl-1H-1,2,4,-triazole]
 57-57-8         beta-Propiolactone                     0.1
 123-38-6        Propionaldehyde                      1.0
 114-26-1        Propoxur                             1.0
                 [Phenol, 2-(l-methylethoxy)-,
                 methylcarbamate]
 115-07-1        Propylene (Propene)                   1.0
 75-55-8         Propyleneimine                       0.1
 75-56-9         Propylene oxide                       0.1
 110-86-1        Pyridine                              1.0
 91-22-5         Quinoline                             1.0
 106-51-4        Quinone                              1.0
 82-68-8         Quintozene                           1.0
                 (Pentachloronitrobenzene)
 76578-14-8      Quizalofop-ethyl                      1.0
                 [2-[4-[(6-Chloro-2-
                 quinoxalinyl)oxy]phenoxy] propanoic acid
                 ethyl ester]
 10453-86-8      Resmethrin                           1.0
	[[5-(Phenylmethyl)-3-furanyl]methyl-2,2-
CAS Number   Chemical Name
Deminimis
  % Limit
                                  dimethyl-3-(2-methyl-l-propenyl)
                                  cyclopropanecarboxylate]
                  81-07-2         Saccharin (only persons who            1.0
                                  manufacture are subject, no supplier
                                  notification)
                  94-59-7         Safrole                               0.1
                  7782-49-2       Selenium                             1.0
                  74051-80-2      Sethoxydim                          1.0
                                  [2-[l-(Ethoxyimino)butyl]-5-[2-
                                  (ethylthio)propyl] -3 -hydroxyl-2-
                                  cyclohexen-1-one]
                  7440-22-4       Silver                                1.0
                  122-34-9        Simazine                             1.0
                  26628-22-8      Sodium azide                         1.0
                  1982-69-0       Sodium dicamba                      1.0
                                  [3,6-Dichloro-2-methoxybenzoic acid,
                                  sodium salt]
                  128-04-1        Sodium dimethyldithiocarbamate        1.0
                  62-74-8         Sodium fluoroacetate                  1.0
                  7632-00-0       Sodium nitrite                         1.0
                  131 -52-2        Sodium pentachlorophenate             1.0
                  132-27-4        Sodium o-phenylphenoxide             0.1
                  100-42-5        Styrene                               0.1
                  96-09-3         Styrene oxide                         0.1
                  7664-93-9       Sulfuric acid                          1.0
                                  (acid aerosols including mists, vapors, gas,
                                  fog, and other airborne forms of any particle
                                  size)
                  2699-79-8       Sulfuryl fluoride (Vikane)              1.0
                  35400-43-2      Sulprofos                             1.0
                                  [O-Ethyl O-[4-(methylthio)phenyl]
                                  phosphorodithioic acid S-propylester]
                  34014-18-1      Tebuthiuron                          1.0
                                  [N-[5-( 1,1 -Dimethylethyl)-1,3,4-thiadiazol-
                                  2-yl] -N,N' -dimethylurea]
                  3383-96-8       Temephos                            1.0
                  5902-51-2       Terbacil                              1.0
                                  [5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
                                  2,4(lH,3H)-pyrimidinedione]
                  79-94-7         Tetrabromobisphenol A                  *
                  630-20-6        1,1,1,2-Tetrachloroethane               1.0
                  79-34-5         1,1,2,2-Tetrachloroethane               1.0
                  127-18-4        Tetrachloroethylene                    0.1
                                  (Perchloroethylene)
                  354-11-0        l,l,l,2-Tetrachloro-2-fluoroethane      1.0
                                  (HCFC-121a)
                  354-14-3        1,1,2,2-Tetrachloro-l-fluoroethane      1.0
                                  (HCFC-121)
                  961-11-5        Tetrachlorvinphos                     1.0
                                  [Phosphoric acid, 2-chloro-l-(2,4,5-
                                  trichlorophenyl) ethenyl dimethyl ester]
                  64-75-5         Tetracycline hydrochloride             1.0
                  7696-12-0       Tetramethrin                          1.0
                                  [2,2-Dimethyl-3-(2-methyl-l-propenyl)
                                  cyclopropanecarboxylic acid (1,3,4,5,6,7-
                                  hexahydro-1,3 -dioxo-2H-isoindol-2-
                 	yl)methyl ester]	
                           Toxics Release Inventory Reporting Form and Instructions
                                                                  II-9

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                             Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number   Chemical Name
                                              Deminimis
                                                % Limit
                                                     1.0
 7440-28-0       Thallium                             1.0
 148-79-8        Thiabendazole                         1.0
                 [2-(4-Thiazolyl)-lH-benzimidazole]
 62-55-5         Thioacetamide                         0.1
 28249-77-6      Thiobencarb                          1.0
                 [Carbamic acid, diethylthio-, S-(p-
                 chlorobenzyl)ester]
 139-65-1        4,4'-Thiodianiline                      0.1
 59669-26-0      Thiodicaib                            1.0
 23564-06-9      Thiophanate ethyl                      1.0
                 [[1,2-Phenylenebis(iminocarbonothioyl)]
                 biscarbamic acid diethylester]
 23564-05-8      Thiophanate methyl                    1.0
 79-19-6         Thiosemicarbazide                     1.0
 62-56-6         Thiourea                             0.1
 137-26-8        Thiram                               1.0
 1314-20-1       Thorium dioxide                       1.0
 7550-45-0       Titanium tetrachloride                  1.0
 108-88-3        Toluene                              1.0
 584-84-9        Toluene-2,4-diisocyanate               0
 91-08-7         Toluene-2,6-diisocyanate               0
 26471-62-5      Toluene diisocyanate (mixed            0
                 isomers)
 95-53-4         o-Toluidine
 636-21-5        o-Toluidine hydrochloride
 8001-35-2       Toxaphene
 43121-43-3      Triadimefon
                 [1-(4-Chlorophenoxy)-3,3-di-methyl-1-(1H-
                 1,2,4- triazol-l-yl)-2-butanone]
 2303-17-5       Triallate                              1.0
 68-76-8         Triaziquone                           1.0
                 [2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
                 aziridinyl)-]
 101200-48-0     Tribenuron methyl                     1.0
                 [2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-2-
                 yl)-methylamino]-carbonyl]amino]sulfonyl]
                 benzoic acid methyl ester)
 1983-10-4       Tributyltin fluoride                     1.0
 2155-70-6       Tributyltin methacrylate                1.0
 78-48-8         S,S,S-Tributyltrithio-                   1.0
                 phosphate (DBF)
 52-68-6         Trichlorfon                            1.0
                 [Phosphoric acid,(2,2,2-trichloro-l-hydroxy-
                 ethyl)-, dimethyl ester]
 76-02-8         Trichloroacetyl chloride                1.0
 120-82-1        1,2,4-Trichlorobenzene                 1.0
 71-55-6         1,1,1-Trichloroethane (Methyl           1.0
                 chloroform)
 79-00-5         1,1,2-Trichloroethane                   1.0
 79-01-6         Trichloroethylene                      0.1
 75-69-4         Trichlorofluoromethane(CFC-ll)       1.0
 95-95-4         2,4,5-Trichlorophenol                  1.0
 88-06-2         2,4,6-Trichlorophenol                  0.1
 96-18-4         1,2,3-Trichloropropane                 0.1
 57213-69-1      Triclopyr triethylammonium salt         1.0
 121-44-8        Triethylamine                         1.0
 1582-09-8       Trifluralin                             *
                 [Benezeneamine, 2,6-dinitro-N,N-dipropyl-
	4-(trifluoromethyl)-1	
CAS Number
26644-46-2


95-63-6
2655-15-4

639-58-7
76-87-9
126-72-7

72-57-1
51-79-6
7440-62-2

50471-44-8


108-05-4
593-60-2
75-01-4
75-35-4
108-38-3
95-47-6
106-42-3
1330-20-7
87-62-7
7440-66-6
12122-67-7


Deminimis
Chemical Name % Limit
Triforine
[N,N'-[l,4-Piperazinediylbis-(2,2,2-
trichloroethylidene)]bisformamide]
1 ,2,4-Trimethylbenzene
2,3,5-Trimethylphenyl
methylcarbamate
Triphenyltin chloride
Triphenyltin hydroxide
Tris(2,3 -dibromopropyl)
phosphate
Trypan blue
Urethane (Ethyl carbamate)
Vanadium (except when contained
in an alloy)
Vinclozolin
[3-(3,5-Dichlorophenyl)-5-ethenyl-5-
methyl-2,4-oxazolidinedione]
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride
m-Xylene
o-Xylene
p-Xylene
Xylene (mixed isomers)
2,6-Xylidine
Zinc (fume or dust)
Zineb
[Carbamodithioic acid, 1,2-ethanediyibis-
zinc complex]
1.0


1.0
1.0

1.0
1.0
0.1

0.1
0.1
1.0

1.0


0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0


                          Toxics Release Inventory Reporting Form and Instructions
                                                                                                              11-10

-------
  Table II. EPCRA Section 313 Chemical List - RY2009


b.




Individually Listed Toxic Chemicals Arranged
by CAS Number

De minimis
CAS Number Chemical Name % Limit
Arranged by CAS Number
50-00-0
51-03-6
51-21-8
51-28-5
51-75-2

51-79-6
52-68-6


52-85-7
53-96-3
55-18-5
55-21-0
55-38-9



55-63-0
56-23-5
56-35-9
56-38-2


57-14-7
57-33-0
57-41-0
57-57-8
57-74-9


58-89-9



59-89-2
60-09-3
60-11-7
60-34-4
60-35-5
60-51-5
61-82-5
62-53-3
62-55-5
62-56-6
62-73-7


62-74-8
62-75-9
63-25-2
Formaldehyde 0.1
Piperonyl butoxide 1.0
Fluorouracil (5-Fluorouracil) 1.0
2,4-Dinitrophenol 1.0
Nitrogen mustard 0 . 1
[2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Urethane (Ethyl carbamate) 0.1
Trichlorfon 1.0
[Phosphonic acid, (2,2,2-trichloro-l-
hydroxy ethyl)-, dimethyl ester]
Famphur 1.0
2-Acetylaminofluorene 0.1
N-Nitrosodiethylamine 0.1
Benzamide 1.0
Fenthion 1.0
[O,O-Dimethyl O-[3-methyl-4-
(methylthio)phenyl] ester, phosphorothioic
acid]
Nitroglycerin 1.0
Carbon tetrachloride 0 . 1
Bis(tributyltin) oxide 1.0
Parathion 1.0
[Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl) ester]
1,1-Dimethylhydrazine 0.1
Pentobarbital sodium 1.0
Phenytoin 0.1
beta-Propiolactone 0.1
Chlordane *
[4,7-Methanoindan, 1,2,4,5,6,7,8,8-
octachloro-2,3,3a,4,7,7a-hexahydro-]
Lindane 0.1
[Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha,
5.alpha.,6.beta.)-]
N-Nitrosomorpholine 0.1
4-Aminoazobenzene 0.1
4-Dimethylaminoazobenzene 0.1
Methyl hydrazine 1.0
Acetamide 0.1
Dimethoate 1.0
Amitrole 0.1
Aniline 1.0
Thioacetamide 0.1
Thiourea 0.1
Dichlorvos 0.1
[Phosphoric acid, 2,2-dichloroethenyl
dimethyl ester]
Sodium fluoroacetate 1.0
N-Nitrosodimethylamine 0.1
Carbaryl 1.0























































De minimis
CAS Number
Chemical Name % Limit
Arranged by CAS Number

64-18-6
64-67-5
64-75-5
67-56-1
67-63-0

[1-Naphthalenol, methylcarbamate]
Formic acid
Diethyl sulfate
Tetracycline hydrochloride
Methanol
Isopropyl alcohol
(only persons who manufacture by the

1.0
0.1
1.0
1.0
1.0

strong acid process are subject, no supplier

67-66-3
67-72-1
68-12-2
68-76-8


70-30-4
71-36-3
71-43-2
71-55-6

72-43-5


72-57-1
74-83-9
74-85-1
74-87-3
74-88-4
74-90-8
74-95-3
75-00-3
75-01-4
75-05-8
75-07-0
75-09-2

75-15-0
75-21-8
75-25-2
75-27-4
75-34-3
75-35-4
75-43-4

75-44-5
75-45-6

75-55-8
75-56-9
75-63-8

75-65-0
75-68-3

75-69-4
75-71-8

75-72-9
notification)
Chloroform
Hexachloroethane
N,N-Dimethylformamide
Triaziquone
[2,5-Cyclohexadiene-l,4-dione, 2,3,5-
tris(l-aziridinyl)-]
Hexachlorophene
n-Butyl alcohol
Benzene
1,1,1 -Trichloroethane (Methyl
chloroform)
Methoxychlor
[Benzene, 1, 1 '-(2,2,2-
trichloroethylidene)bis[4-methoxy-]
Trypan blue
Bromomethane (Methyl bromide)
Ethylene
Chloromethane (Methyl chloride)
Methyl iodide
Hydrogen cyanide
Methylene bromide
Chloroethane (Ethyl chloride)
Vinyl chloride
Acetonitrile
Acetaldehyde
Dichloromethane (Methylene
chloride)
Carbon disulfide
Ethylene oxide
Bromoform (Tribromomethane)
Dichlorobromomethane
Ethylidene dichloride
Vinylidene chloride
Dichlorofluoromethane
(HCFC-21)
Phosgene
Chlorodifluoromethane
(HCFC-22)
Propyleneimine
Propylene oxide
Bromotrifluoromethane
(Halon 1301)
tert-Butyl alcohol
1 -Chloro- 1 , 1 -difluoroethane
(HCFC-142b)
Trichlorofluoromethane (CFC-11)
Dichlorodifluoromethane
(CFC-12)
Chlorotrifluoromethane (CFC-13)

0.1
0.1
1.0
1.0


1.0
1.0
0.1
1.0

*


0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
0.1

1.0
0.1
1.0
0.1
1.0
1.0
1.0

1.0
1.0

0.1
0.1
1.0

1.0
1.0

1.0
1.0

1.0
Toxics Release Inventory Reporting Form and Instructions
11-11

-------
                              Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number   Chemical Name
De minimis
   % Limit
                Arranged by CAS Number
75-86-5         2-Methyllactonitrile
75-88-7         2-Chloro-l,l,l-trifluoroethane
                (HCFC-133a)
76-01-7         Pentachloroethane
76-02-8         Trichloroacetyl chloride
76-06-2         Chloropicrin
76-13-1         FreonllS
                [Ethane, l,l,2-trichloro-l,2,2,-trifluoro-]
76-14-2         Dichlorotetrafluoroethane             1.0
                (CFC-114)
76-15-3         Monochloropentafluoroethane         1.0
                (CFC-115)
76-44-8         Heptachlor                           *
                [l,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-
                tetrahydro-4,7-methano-lH-indene]
76-87-9         Triphenyltin hydroxide                1.0
77-47-4         Hexachlorocyclopentadiene           1.0
77-73-6         Dicyclopentadiene                    1.0
77-78-1         Dimethyl sulfate                     0.1
78-48-8         S,S,S-Tributyltrithiophosphate         1.0
                (DBF)
78-84-2         Isobutyraldehyde                     1.0
78-87-5         1,2-Dichloropropane                  1.0
78-88-6         2,3-Dichloropropene                  1.0
78-92-2         sec-Butyl alcohol                     1.0
79-00-5         1,1,2-Trichloroethane                 1.0
79-01-6         Trichloroethylene                     0.1
79-06-1         Acrylamide                          0.1
79-10-7         Aery lie acid                         1.0
79-11-8         Chloroacetic acid                     1.0
79-19-6         Thiosemicarbazide                    1.0
79-21-0         Peracetic acid                        1.0
79-22-1         Methyl chlorocarbonate               1.0
79-34-5         1,1,2,2-Tetrachloroethane             1.0
79-44-7         Dimethylcarbamyl chloride            0.1
79-46-9         2-Nitropropane                      0.1
79-94-7         Tetrabromobisphenol A                *
80-05-7         4,4'-Isopropylidenediphenol           1.0
80-15-9         Cumene hydroperoxide                1.0
80-62-6         Methyl methacry late                  1.0
81-07-2         Saccharin (only persons who          1.0
                manufacture are subject, no supplier
                notification)
81-88-9         C.I. Food Red  15                     1.0
82-28-0         l-Amino-2-methylanthraquinone       0.1
82-68-8         Quintozene                          1.0
                [Pentachloronitrobenzene]
84-74-2         Dibutyl phthalate                     1.0
85-01-8         Phenanthrene                        1.0
85-44-9         Phthalic anhydride                    1.0
86-30-6         N-Nitrosodiphenylamine              1.0
87-62-7         2,6-Xylidine                         0.1
87-68-3         Hexachloro-1,3-butadiene             1.0
87-86-5         Pentachlorophenol (PCP)              0.1
88-06-2         2,4,6-Trichlorophenol                0.1
88-75-5         2-Nitrophenol                        1.0
88-85-7         Dinitrobutyl phenol (Dinoseb)         1.0
88-89-1         Picric acid                          1.0
CAS Number   Chemical Name
De minimis
   % Limit
                                    Arranged by CAS Number
                   90-04-0         o-Anisidine                         0.1
                   90-43-7         2-Phenylphenol                      1.0
                   90-94-8         Michler's ketone                     0.
                   91-08-7         Toluene-2,6-diisocyanate             0.
                   91-20-3         Naphthalene                         0.
                   91-22-5         Quinoline                           1.0
                   91-59-8         beta-Naphthylamine                  0.
                   91-94-1         3,3'-Dichlorobenzidine               0.
                   92-52-4         Biphenyl                            1.0
                   92-67-1         4-Aminobiphenyl                    0.
                   92-87-5         Benzidine                           0.
                   92-93-3         4-Nitrobiphenyl                      0.
                   93-65-2         Mecoprop                           0.
                   94-11-1         2,4-D isopropyl ester                 0.
                   94-36-0         Benzoyl peroxide                    1.0
                   94-58-6         Dihydrosafrole                      0.
                   94-59-7         Safrole                             0.
                   94-74-6         Methoxone                          0.
                                   ((4-Chloro-2-methylphenoxy) acetic acid)
                                   (MCPA)
                   94-75-7         2,4-D [Acetic acid, (2,4-              0.1
                                   dichlorophenoxy)-]
                   94-80-4         2,4-D butyl ester                     0.1
                   94-82-6         2,4-DB                             1.0
                   95.47-6         o-Xylene                            1.0
                   95-48-7         o-Cresol                            1.0
                   95-50-1         1,2-Dichlorobenzene                 1.0
                   95-53-4         o-Toluidine                         0.1
                   95-54-5         1,2-Phenylenediamine                1.0
                   95-63-6         1,2,4-Trimethylbenzene               1.0
                   95-69-2         p-Chloro-o-toluidine                 0.1
                   95-80-7         2,4-Diaminotoluene                  0.1
                   95-95-4         2,4,5-Trichlorophenol                1.0
                   96-09-3         Styrene oxide                        0.1
                   96-12-8         l,2-Dibromo-3-chloropropane         0.1
                                   (DBCP)
                   96-18-4         1,2,3-Trichloropropane               0.1
                   96-33-3         Methyl aery late                      1.0
                   96-45-7         Ethylene thiourea                    0.1
                   97-23-4         Dichlorophene                      1.0
                                   [2,2'-Methylenebis(4-chlorophenol)]
                   97-56-3         C.I. Solvent Yellow 3                 0.1
                   98-07-7         Benzoic trichloride                   0.1
                                   (Benzotrichloride)
                   98-82-8         Cumene                            1.0
                   98-86-2         Acetophenone                       1.0
                   98-87-3         Benzal chloride                      1.0
                   98-88-4         Benzoyl chloride                     1.0
                   98-95-3         Nitrobenzene                        0.1
                   99-30-9         Dichloran [2,6-Dichloro-4-            1.0
                                   nitroaniline]
                   99-55-8         5-Nitro-o-toluidine                   1.0
                   99-59-2         5-Nitro-o-anisidine                   1.0
                   99-65-0         m-Dinitrobenzene                    1.0
                   100-01-6        p-Nitroaniline                       1.0
                   100-02-7        4-Nitrophenol                       1.0
                   100-25-4        p-Dinitrobenzene                    1.0
                   100-41-4	Ethylbenzene	0.1
                           Toxics Release Inventory Reporting Form and Instructions
                                                                    11-12

-------
                              Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number   Chemical Name
De minimis
   % Limit
                Arranged by CAS Number
100-42-5        Styrene                             0.1
100-44-7        Benzyl chloride                     1.0
100-75-4        N-Nitrosopiperidine                 0.1
101-05-3        Anilazine                           1.0
                [4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-
                triazin-2-amine]
101-14-4        4,4'-Methylenebis(2-chloroanirine)     0.1
                (MBOCA)
101-61-1        4,4'-Methylenebis(N,N-              0.1
                dimethyl)benzenamine
101-77-9        4,4'-Methylenedianiline              0.1
101-80-4        4,4'-Diaminodiphenyl ether           0.1
101-90-6        Diglycidyl resorcinol ether           0.1
104-12-1        p-Chlorophenyl isocyanate           1.0
104-94-9        p-Anisidine                         1.0
105-67-9        2,4-Dimethylphenol                 1.0
106-42-3        p-Xylene                           1.0
106-44-5        p-Cresol                            1.0
106-46-7        1,4-Dichlorobenzene                 0.1
106-47-8        p-Chloroaniline                     0.1
106-50-3        p-Phenylenediamine                 1.0
106-51-4        Quinone                            1.0
106-88-7        1,2-Butylene oxide                  0.1
106-89-8        Epichlorohydrin                     0.1
106-93-4        1,2-Dibromoethane                  0.1
                (Ethylene dibromide)
106-99-0        1,3-Butadiene                       0.1
107-02-8        Acrolein                            1.0
107-05-1        Allyl chloride                       1.0
107-06-2        1,2-Dichloroethane (Ethylene         0.1
                dichloride)
107-11-9        Allylamine                         1.0
107-13-1        Acrylonitrile                        0.1
107-18-6        Allyl alcohol                        1.0
107-19-7        Propargyl alcohol                    1.0
107-21-1        Ethylene glycol                     1.0
107-30-2        Chloromethyl methyl ether           0.1
108-05-4        Vinyl acetate                        0.1
108-10-1        Methyl isobutyl ketone                .0
108-31-6        Maleic anhydride
108-38-3        m-Xylene
108-39-4        m-Cresol
108-45-2        1,3-Phenylenediamine
108-60-1        Bis(2-chloro-l-methylethyl) ether
108-88-3        Toluene
108-90-7        Chlorobenzene
108-93-0        Cyclohexanol
108-95-2        Phenol
109-06-8        2-Methylpyridine
109-77-3        Malononitrile
109-86-4        2-Methoxyethanol
110-54-3        n-Hexane
110-57-6        trans-l,4-Dichloro-2-butene
110-80-5        2-Ethoxyethanol
110-82-7        Cyclohexane
110-86-1        Pyridine
111 -42-2        Diethanolamine
111-44-4	Bis(2-chloroethyl) ether	
CAS Number   Chemical Name
De minimis
   % Limit
                                   Arranged by CAS Number
                   111-91-1        Bis(2-chloroethoxy) methane          1.0
                   114-26-1        Propoxur                            1.0
                                   [Phenol, 2-(l-methylethoxy)-,
                                   methylcarbamate]
                   115-07-1        Propylene (Propene)                  1.0
                   115-28-6        Chlorendic acid                      0.1
                   115-32-2        Dicofol                             1.0
                                   [Benzenemethanol, 4-chloro-.alpha.-4-
                                   (chlorophenyl)-.alpha.-(trichloromethyl)-]
                   116-06-3        Aldicarb                             1.0
                   117-79-3        2-Aminoanthraquinone                0.1
                   117-81-7        Di(2-ethylhexyl) phthalate             0.1
                   118-74-1        Hexachlorobenzene                   *
                   119-90-4        3,3'-Dimethoxybenzidine              0.1
                   119-93-7        3,3'-Dimethylbenzidine                0.1
                                   (o-Tolidine)
                   120-12-7        Anthracene                          1.0
                   120-36-5        2,4-DP                              0.1
                   120-58-1        Isosafrole                           1.0
                   120-71-8        p-Cresidine                          0.1
                   120-80-9        Catechol                             0.1
                   120-82-1        1,2,4-Trichlorobenzene                1.0
                   120-83-2        2,4-Dichlorophenol                  1.0
                   121-14-2        2,4-Dinitrotoluene                    0.1
                   121-44-8        Triethylamine                        1.0
                   121-69-7        N,N-Dimethylaniline                  1.0
                   121-75-5        Malathion                           1.0
                   122-34-9        Simazine                            1.0
                   122-39-4        Diphenylamine                       1.0
                   122-66-7        1,2-Diphenylhydrazine                0.1
                                   (Hydrazobenzene)
                   123-31-9        Hydroquinone                        1.0
                   123-38-6        Propionaldehyde                     1.0
                   123-63-7        Paraldehyde                          1.0
                   123-72-8        Butyraldehyde                       1.0
                   123-91-1        1,4-Dioxane                          0.1
                   124-40-3        Dimethylamine                       1.0
                   124-73-2        Dibromotetrafluoroethane             1.0
                                   (Halon2402)
                   126-72-7        Tris(2,3-dibromopropyl)              0.1
                                   phosphate
                   126-98-7        Methacrylonitrile                     1.0
                   126-99-8        Chloroprene                          0.1
                   127-18-4        Tetrachloroethylene                  0.1
                                   (Perchloroethylene)
                   128-03-0        Potassium                           1.0
                                   dimethyldithiocarbamate
                   128-04-1        Sodium dimethyldithiocarbamate       1.0
                   128-66-5        C.I. Vat Yellow 4                    1.0
                   131-11-3        Dimethyl phthalate                   1.0
                   131-52-2        Sodium pentachlorophenate           1.0
                   132-27-4        Sodium o-phenylphenoxide           0.1
                   132-64-9        Dibenzofuran                        1.0
                   133-06-2        Captan                              1.0
                                   [IH-Isoindole-1,3(2H)-dione, 3a,4,7,7a-
                                   tetrahydro-2-[(trichloromethyl)thio]-]
                   133-07-3        Folpet                              1.0
                   133-90-4        Chloramben                          1.0
                           Toxics Release Inventory Reporting Form and Instructions
                                                                   11-13

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  Table II. EPCRA Section 313 Chemical List - RY2009

CAS Number
De minimis
Chemical Name % Limit
Arranged by CAS Number

134-29-2
134-32-7
135-20-6


136-45-8
137-26-8
137-41-7

137-42-8

138-93-2

139-13-9
139-65-1
140-88-5
141-32-2
142-59-6
148-79-8

149-30-4

150-50-5
150-68-5
151-56-4
156-10-5
156-62-7
191-24-2
298-00-0
300-76-5
301-12-2


302-01-2
306-83-2

309-00-2




314-40-9


319-84-6
330-54-1
330-55-2
333-41-5
334-88-3
353-59-3

354-11-0

354-14-3

354-23-4

[Benzole acid, 3-amino-2,5-dichloro-]
o-Anisidine hydrochloride 0.1
alpha-Naphthylamine 0.1
Cupferron 0.1
[Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Dipropyl isocinchomeronate 1.0
Thiram 1.0
Potassium N-methyldithio- 1.0
carbamate
Metham sodium (Sodium 1.0
methyldithiocarbamate)
Disodium cyanodithioimido- 1.0
carbonate
Nitrilotriacetic acid 0.1
4,4'-Thiodianiline 0.1
Ethyl aery late 0.1
Butyl aery late 1.0
Nabam 1.0
Thiabendazole 1.0
[2-(4-Thiazolyl)-lH-benzimidazole]
2-Mercaptobenzothiazole 1.0
(MET)
Merphos 1.0
Monuron 1.0
Ethyleneimine (Aziridine) 0.1
p-Nitrosodiphenylamine 1.0
Calcium cyanamide 1.0
Benzo(g,h,i)perylene *
Methyl parathion 1.0
Naled 1.0
Oxydemeton methyl 1.0
[S-(2-(Ethylsuffinyl)ethyl)O,O-dimethyl
ester phosphorothioic acid]
Hydrazine 0.1
2,2-Dichloro- 1 ,1,1 -trifluoroethane 1 .0
(HCFC-123)
Aldrin *
[ 1 ,4 : 5,8-Dimethanonaphthalene,
l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a-
hexahydro-(l.alpha.,4.alpha.,4a.beta.,
5.alpha.,8.alpha.,8a.beta.)-]
Bromacil 1.0
(5-Bromo-6-methyl-3-(l-methylpropyl)-
2,4(lH,3H)-pyrimidinedione)
alpha-Hexachlorocyclohexane 0.1
Diuron .0
Linuron .0
Diazinon .0
Diazomethane .0
Bromochlorodifluoromethane .0
(Halonl211)
1,1, 1 ,2-Tetrachloro-2-fluoroethane 1 .0
(HCFC-121a)
1 , 1 ,2,2-Tetrachloro- 1 -fluoroethane 1 .0
(HCFC-121)
l,2-Dichloro-l,l,2- 1.0
trifluoroethane (HCFC-123a)





























































De minimis
CAS Number
Chemical Name %
Limit
Arranged by CAS Number
354-25-6

357-57-3
422-44-6

422-48-0

422-56-0

431-86-7

460-35-5

463-58-1
465-73-6
492-80-8

505-60-2

507-55-1

510-15-6

l-Chloro-1,1,2,2-
tetrafluoroethane (HCFC-124a)
Brucine
1,2-Dichloro-l, 1,2,3,3-
pentafluoropropane (HCFC-225bb)
2,3-Dichloro-l, 1,1,2,3-
pentafluoropropane (HCFC-225ba)
3,3-Dichloro-l, 1,1,2,2-
pentafluoropropane (HCFC-225ca)
1,2-Dichloro-l, 1,3,3,3-
pentafluoropropane (HCFC-225da)
3 -Chloro- 1 ,1,1 -trifluoropropane
(HCFC-253fb)
Carbonyl sulfide
Isodrin
C.I. Solvent Yellow 34
(Auramine)
Mustard gas
[Ethane, l,l'-thiobis[2-chloro-]
1,3-Dichloro-l, 1,2,2,3-
pentafluoropropane (HCFC-225cb)
Chlorobenzilate
[Benzeneacetic acid, 4-chloro-.alpha
1.0

1.0
1.0

1.0

1.0

1.0

1.0

1.0
*
0.1

0.1

1.0

1.0
-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl

528-29-0
532-27-4
533-74-4


534-52-1
540-59-0
541-41-3
541-53-7
541-73-1
542-75-6
542-76-7
542-88-1
554-13-2
556-61-6

563-47-3
569-64-2
584-84-9
593-60-2
594-42-3
606-20-2
608-93-5
612-82-8


612-83-9

615-05-4
615-28-1

621-64-7
624-18-0
ester]
o-Dinitrobenzene
2-Chloroacetophenone
Dazomet
(Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione)
4,6-Dinitro-o-cresol
1 ,2-Dichloroethylene
Ethyl chloroformate
2,4-Dithiobiuret
1 , 3 -Dichlorobenzene
1 , 3 -Dichloropropy lene
3 -Chloropropionitrile
Bis(chloromethyl) ether
Lithium carbonate
Methyl isothiocyanate
[Isothiocyanatomethane]
3 -Chloro-2 -methyl- 1 -propene
C.I. Basic Green 4
Toluene-2,4-diisocyanate
Vinyl bromide
Perchloromethyl mercaptan
2,6-Dinitrotoluene
Pentachlorobenzene
3 , 3 '-Dimethylbenzidine
dihydrochloride (o-Tolidine
dihydrochloride)
3 , 3 '-Dichlorobenzidine
dihydrochloride
2,4-Diaminoanisole
1 ,2-Phenylenediamine
dihydrochloride
N-Nitrosodi-n-propylamine
1 ,4-Phenylenediamine

1.0
1.0
1.0


1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0

0.1
1.0
0.1
0.1
1.0
0.1
*
0.1


0.1

0.1
1.0

0.1
1.0
Toxics Release Inventory Reporting Form and Instructions
11-14

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                               Table II. EPCRA Section 313 Chemical List - RY2009
 CAS Number   Chemical Name
De minimis
   % Limit
                 Arranged by CAS Number
                 dihydrochloride
 624-83-9        Methyl isocyanate                   1.0
 630-20-6        1,1,1,2-Tetrachloroethane            1.0
 636-21-5        o-Toluidine hydrochloride            0.1
 639-58-7        Triphenyltin chloride                 1.0
 680-31-9        Hexamethylphosphoramide           0.1
 684-93-5        N-Nitroso-N-methylurea             0.1
 709-98-8        Propanil (N-(3,4-Dichlorophenyl)     1.0
                 propanamide)
 759-73-9        N-Nitroso-N-ethylurea               0.1
 759-94-4        Ethyl dipropylthiocarbamate          1.0
                 (EPTC)
 764-41-0        l,4-Dichloro-2-butene                1.0
 812-04-4        l,l-Dichloro-l,2,2-trifluoroethane     1.0
                 (HCFC-123b)
 834-12-8        Ametryn                           1.0
                 (N-Ethyl-N' -(1 -methylethyl)-6-
                 (methylthio)-l,3,5,-triazine-2,4-diamine)
 842-07-9        C.I. Solvent Yellow 14               1.0
 872-50-4        N-Methyl-2-pyrrolidone              1.0
 924-16-3        N-Nitrosodi-n-butylamine            0.1
 924-42-5        N-Methylolacrylamide               1.0
 957-51-7        Diphenamid                        1.0
 961-11-5        Tetrachlorvinphos                   1.0
                 [Phosphoric acid, 2-chloro-l-(2,4,5-
                 trichlorophenyl)ethenyldimethyl ester]
 989-38-8        C.I. Basic Red 1                     1.0
 1114-71-2       Pebulate                            1.0
                 [Butylethylcarbamothioic acid S-propyl
                 ester]
 1120-71-4       Propane sultone                     0.1
 1134-23-2       Cycloate                            .0
 1163-19-5       Decabromodiphenyl oxide             .0
 1313 -27-5       Molybdenum trioxide                 .0
 1314-20-1       Thorium dioxide                     .0
 1319-77-3       Cresol (mixed isomers)                .0
 1320-18-9       2,4-D propylene glycol butyl          0.1
                 ether ester
 1330-20-7       Xylene (mixed isomers)              1.0
 1332-21-4       Asbestos (friable)                    0.1
 1335-87-1       Hexachloronaphthalene              1.0
 1336-36-3       Polychlorinated biphenyls (PCBs)       *
 1344-28-1       Aluminum oxide (fibrous forms)       1.0
 1464-53-5       Diepoxybutane                      0.1
 1563-66-2       Carbofuran                         1.0
 1582-09-8       Trifluralin                            *
                 [Benezeneamine, 2,6-dinitro-N,N-
                 dipropyl-4-(trifluoromethyl)-]
 1634-04-4       Methyl tert-butyl ether               1.0
 1649-08-7       l,2-Dichloro-l,l-difluoroethane       1.0
                 (HCFC-132b)
 1689-84-5       Bromoxynil                        1.0
                 (3,5-Dibromo-4-hydroxybenzonitrile)
 1689-99-2       Bromoxynil octanoate                1.0
                 (Octanoic acid, 2,6-dibromo-4-
                 cyanophenyl ester)
 1717-00-6       1,1-Dichloro-l-fluoroethane          1.0
	(HCFC-141b)	
CAS Number   Chemical Name
De minimis
   % Limit
                                   Arranged by CAS Number
                   1836-75-5       Nitrofen                           0.1
                                   [Benzene, 2,4-dichloro-l-(4-
                                   nitrophenoxy)-]
                   1861-40-1       Benfluralin                         1.0
                                   (N-Butyl-N-ethyl-2,6-dinitro-4-
                                   (trifluoromethyl)benzenamine)
                   1897-45-6       Chlorothalonil                      0.1
                                   [1,3-Benzenedicarbonitrile, 2,4,5,6-
                                   tetrachloro-]
                   1910-42-5       Paraquat dichloride                  1.0
                   1912-24-9       Atrazine                           1.0
                                   (6-Chloro-N-ethyl-N'-(l-methylethyl)-
                                   l,3,5-triazine-2,4-diamine)
                   1918-00-9       Dicamba                           1.0
                                   (3,6-Dichloro-2-methoxybenzoic acid)
                   1918-02-1       Picloram                           1.0
                   1918-16-7       Propachlor                          1.0
                                   [2-Chloro-N-(l-methylethyl)-N-
                                   phenylacetamide]
                   1928-43-4       2,4-D 2-ethylhexyl ester             0.1
                   1929-73-3       2,4-D butoxyethyl ester              0.1
                   1929-82-4       Nitrapyrin                          1.0
                                   (2-Chloro-6-(trichloromethyl)pyridine)
                   1937-37-7       C.I. Direct Black 38                 0.1
                   1982-69-0       Sodium dicamba                    1.0
                                   [3,6-Dichloro-2-methoxybenzoic acid,
                                   sodium salt]
                   1983-10-4       Tributyltin fluoride                  1.0
                   2032-65-7       Methiocarb                         1.0
                   2155-70-6       Tributyltin methacrylate             1.0
                   2164-07-0       Dipotassium endothall               1.0
                                   [7-Oxabicyclo(2.2. l)heptane-2,3-
                                   dicarboxylic acid, dipotassium salt]
                   2164-17-2       Fluometuron                       1.0
                                   [Urea, N,N-dimethyl-N'-[3-
                                   (trifluoromethyl)phenyl] -]
                   2212-67-1       Molinate                           1.0
                                   (lH-Azepine-1-carbothioic acid,
                                   hexahydro-S-ethyl ester)
                   2234-13-1       Octachloronaphthalene               1.0
                   2300-66-5       Dimethylamine dicamba             1.0

                   2303-16-4       Diallate                            1.0
                                   [Carbamothioic acid, bis(l-methylethyl)-S-
                                   (2,3-dichloro-2-propenyl) ester]
                   2303-17-5       Triallate                           1.0
                   2312-35-8       Propargite                          1.0
                   2439-01-2       Chinomethionat                     1.0
                                   [6-Methyl-l,3-dithiolo[4,5-b]quinoxalin-2-
                                   one]
                   2439-10-3       Dodine                            1.0
                                   [Dodecylguanidine monoacetate]
                   2524-03-0       Dimethyl chlorothiophosphate        1.0
                   2602-46-2       C.I. Direct Blue 6                   0.1
                   2655-15-4       2,3,5-Trimethylphenyl methyl        1.0
                                   carbamate
                   2699-79-8       Sulfuryl fluoride  (Vikane)            1.0
                   2702-72-9       2,4-D sodium salt	0.1
                            Toxics Release Inventory Reporting Form and Instructions
                                                                   11-15

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                              Table II. EPCRA Section 313 Chemical List - RY2009
CAS Number   Chemical Name
De minimis
   % Limit
                Arranged by CAS Number
2832-40-8       C.I. Disperse Yellow 3               1.0
2837-89-0       2-Chloro-l, 1,1,2-                    1.0
                tetrafluoroethane (HCFC-124)
2971-38-2       2,4-D Chlorocrotyl ester              0.1
3118-97-6       C.I. Solvent Orange 7                1.0
3383-96-8       Temephos                          1.0
3653-48-3       Methoxone sodium salt              0.1
                ((4-Chloro-2-methylphenoxy) acetate
                sodium salt)
3761-53-3       C.I. Food Red 5                     0.1
4080-31-3       l-(3-Chloroallyl)-3,5,7-triaza-l-       1.0
                azoniaadamantane chloride
4170-30-3       Crotonaldehyde                     1.0
4549-40-0       N-Nitrosomethylvinylamine          0.1
4680-78-8       C.I. Acid Green 3                    1.0
5234-68-4       Carboxin                           1.0
                (5,6-Dihydro-2-methyl-N-phenyl-l,4-
                oxathiin-3 -carboxamide)
5598-13-0       Chlorpyrifos methyl                  1.0
                [O,O-Dimethyl-O-(3,5,6-trichloro-2-
                pyridyl)phosphorothioate]
5902-51-2       Terbacil                            1.0
                [5-Chloro-3 -(1,1 -dimethylethyl)-6-methyl-
                2,4(lH,3H)-pyrimidinedione]
6459-94-5       C.I. Acid Red 114                   0.1
7287-19-6       Prometryn                          1.0
                [N,N'-Bis(l-methylethyl)-6-methylthio-
                1,3,5-triazine-2,4-diamine]
7429-90-5       Aluminum (fume or dust)             1.0
7439-92-1       Lead                                 *
                (when lead is contained in stainless steel,
                brass or bronze alloys the de minimis level
                is 0.1)
7439-96-5       Manganese                         1.0
7439-97-6       Mercury                              *
7440-02-0       Nickel                             0.1
7440-22-4       Silver                             1.0
7440-28-0       Thallium                           1.0
7440-36-0       Antimony                          1.0
7440-38-2       Arsenic                            0.1
7440-39-3       Barium                            1.0
7440-41-7       Beryllium                          0.1
7440-43-9       Cadmium                          0.1
7440-47-3       Chromium                          1.0
7440-48-4       Cobalt                             0.1
7440-50-8       Copper
7440-62-2       Vanadium (except when contained
                in an alloy)
7440-66-6       Zinc (fume or dust)
7550-45-0       Titanium tetrachloride
7632-00-0       Sodium nitrite
7637-07-2       Boron trifluoride
7647-01-0       Hydrochloric acid
                (acid aerosols including mists, vapors, gas,
                fog, and other airborne forms of any
                particle size)
7664-39-3       Hydrogen fluoride                   1.0
7664-41-7       Ammonia                          1.0
CAS Number   Chemical Name
De minimis
   % Limit
                                   Arranged by CAS Number
                                   (includes anhydrous ammonia and aqueous
                                   ammonia from water dissociable
                                   ammonium salts and other sources; 10
                                   percent of total aqueous ammonia is
                                   reportable under this listing)
                   7664-93-9       Sulfuric acid                         1.0
                                   (acid aerosols including mists, vapors, gas,
                                   fog, and other airborne forms of any
                                   particle size)
                   7696-12-0       Tetramethrin                         1.0
                                   [2,2-Dimethyl-3-(2-methyl-l-
                                   propenyl)cyclopropanecarboxylic acid
                                   (l,3,4,5,6,7-hexahydro-l,3-dioxo-2H-
                                   isoindol-2-yl)methyl ester]
                   7697-37-2       Nitric acid                           1.0
                   7723-14-0       Phosphorus (yellow or white)          1.0
                   7726-95-6       Bromine                            1.0
                   7758-01-2       Potassium bromate                   0.1
                   7782-41-4       Fluorine                             1.0
                   7782-49-2       Selenium                            1.0
                   7782-50-5       Chlorine                            1.0
                   7786-34-7       Mevinphos                          1.0
                   7803-51-2       Phosphine                           1.0
                   8001-35-2       Toxaphene                            *
                   8001-58-9       Creosote                            0.1
                   9006-42-2       Metiram                            1.0
                   10028-15-6      Ozone                              1.0
                   10034-93-2      Hydrazine sulfate                     0.1
                   10049-04-4      Chlorine dioxide                      1.0
                   10061-02-6      trans-l,3-Dichloropropene             0.1
                   10294-34-5      Boron trichloride                     1.0
                   10453-86-8      Resmethrin                          1.0
                                   [[5-(Phenylmethyl)-3-furanyl]methyl- 2,2-
                                   dimethy 1-3 -(2-methyl-1 -propeny 1)
                                   cy clopropanecarboxy late] ]
                   12122-67-7      Zineb                               1.0
                                   [Carbamodithioic acid, 1,2-ethanediylbis-,
                                   zinc complex]
                   12427-38-2      Maneb                              1.0
                                   [Carbamodithioic acid, 1,2-ethanediylbis-,
                                   manganese complex]
                   13194-48-4      Ethoprop                            1.0
                                   [Phosphorodithioic acid O-ethyl S,S-
                                   dipropyl ester]
                   13356-08-6      Fenbutatin oxide                      1.0
                                   (Hexakis(2-methyl-2-phenylpropyl)
                                   distannoxane)
                   13463-40-6      Iron pentacarbonyl                   1.0
                   13474-88-9      l,l-Dichloro-l,2,2,3,3-               1.0
                                   pentafluoropropane (HCFC-225cc)
                   13684-56-5      Desmedipham                       1.0
                   14484-64-1      Ferbam                              1.0
                                   [Tris(dimethy Icarbamodithioato -S, S' )iron]
                   15972-60-8      Alachlor                            1.0
                   16071-86-6      C.I. Direct Brown 95                  0.1
                   16543-55-8      N-Nitrosonornicotine                 0.1
                   17804-35-2      Benomyl                            1.0
                   19044-88-3      Oryzalin	1.0
                           Toxics Release Inventory Reporting Form and Instructions
                                                                   11-16

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                               Table II. EPCRA Section 313 Chemical List - RY2009
 CAS Number   Chemical Name
De minimis
   % Limit
                 Arranged by CAS Number
                 [4-(Dipropylamino)-3,5-
                 dinitrobenzenesulfonamide]
 19666-30-9      Oxydiazon                          1.0
                 [3-[2,4-Dichloro-5-(l-methylethoxy)
                 phenyl]-5-(l,l-dimethylethyl)-l,3,4-
                 oxadiazol-2(3H)-one]
 20325-40-0      3,3'-Dimethoxybenzidine              0.1
                 dihydrochloride (o-Dianisidine
                 dihydrochloride)
 20354-26-1      Methazole                           1.0
                 [2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
                 oxadiazolidine-3,5 -dione]
 20816-12-0      Osmium tetroxide
 20859-73-8      Aluminum phosphide
 21087-64-9      Metribuzin
 21725-46-2      Cyanazine
 22781-23-3      Bendiocarb
                 [2,2-Dimethyl-l,3-benzodioxol-4-ol
                 methylcarbamate]
 23564-05-8      Thiophanate methyl                   1.0
 23564-06-9      Thiophanate ethyl                    1.0
                 [[l,2-Phenylenebis(iminocarbonothioyl)]
                 biscarbamic acid diethyl ester]
 23950-58-5      Pronamide                          1.0
 25311-71-1      Isofenphos                          1.0
                 [2-[[Ethoxyl[( 1 -methylethyl)-
                 amino]phosphinothioyl]oxy]benzoic acid
                 1-methylethyl ester]
 25321-14-6      Dinitrotoluene (mixed isomers)        1.0
 25321-22-6      Dichlorobenzene (mixed isomers)      0.1
 25376-45-8      Diaminotoluene (mixed isomers)       0.1
 26002-80-2      Phenothrin                          1.0
                 [2,2-Dimethyl-3 -(2-methyl-l -
                 propenyl)cyclopropanecarboxylic acid (3-
                 phenoxyphenyl)methyl ester]

 26471-62-5      Toluene diisocyanate                 0.1
                 (mixed isomers)
 26628-22-8      Sodium azide                        1.0
 26644-46-2      Triforine                             1.0
                 [N,N'-[l,4-Piperazinediylbis (2,2,2-
                 trichloroethylidene)]bisformamide]
 27314-13-2      Norflurazon                         1.0
                 [4-Chloro-5-(methylamino)-2-[3-
                 (trifluoromethyl)phenyl] -3 (2H)-
                 pyridazinone]
 28057-48-9      d-trans-Allethrin                     1.0
                 [d-trans-Chrysanthemic acid of d-
                 allethrone]
 28249-77-6      Thiobencarb                         1.0
                 [Carbamic acid, diethylthio-, S-(p-
                 chlorobenzyl)ester]
 28407-37-6      C.I. Direct Blue 218                   1.0
 29082-74-4      Octachlorostyrene                     *
 29232-93-7      Pirimiphos methyl                    1.0
                 [O-(2-(Diethylamino)-6-methyl-4-
                 pyrimidinyl)-O,O-
	dimethylphosphorothioate]	
CAS Number   Chemical Name
De minimis
   % Limit
                                    Arranged by CAS Number
                   30560-19-1      Acephate                            1.0
                                   (Acetylphosphoramidothioic acid O,S-
                                   dimethyl ester)
                   31218-83-4      Propetamphos                       1.0
                                   [3-[(Ethylamino)
                                   methoxyphosphinothioyl]oxy]-2-butenoic
                                   acid, 1-methylethyl ester]
                   33089-61-1      Amitraz                             1.0
                   34014-18-1      Tebuthiuron                         1.0
                                   [N-[5-(l,l-Dimethylethyl)-l,3,4-
                                   thiadiazol-2-yl] -N,N' -dimethylurea]
                   34077-87-7      Dichlorotrifluoroethane               1.0
                   35367-38-5      Diflubenzuron                       1.0
                   35400-43-2      Sulprofos                            1.0
                                   [O-Ethyl O-[4-(methylthio)phenyl]-
                                   phosphorodithioic acid S-propyl ester]
                   35554-44-0      Imazalil                             1.0
                                   [l-[2-(2,4-Dichlorophenyl)-2-(2-
                                   propenyloxy)ethyl] -IH-imidazole]
                   35691-65-7      l-Bromo-l-(bromomethyl)-l,3-        1.0
                                   propanedicarbonitrile
                   38727-55-8      Diethatyl ethyl                       1.0
                   39156-41-7      2,4-Diaminoanisole sulfate            0.1
                   39300-45-3      Dinocap                             1.0
                   39515-41-8      Fenpropathrin                       1.0
                                   [2,2,3,3 -Tetramethy Icy clopropane
                                   carboxylic acid cyano(3-
                                   phenoxyphenyl)methyl ester]
                   40487-42-1      Pendimethalin                        *
                                   [N-( 1 -Ethylpropyl)-3,4-dimethyl-2,6-
                                   dinitrobenzenamine]
                   41198-08-7      Profenofos                          1.0
                                   [O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
                                   propyl phosphorothioate]
                   41766-75-0      3,3'-Dimethylbenzidine               0.1
                                   dihydrofluoride (o-
                                   Tolidinedihydrofluoride)
                   42874-03-3      Oxyfluorfen                         1.0
                   43121-43-3      Triadimefon                         1.0
                                   [l-(4-Chlorophenoxy)-3,3-dimethyl-1-(1H-
                                   1,2,4-triazol-1-yl)-2-butanone]
                   50471-44-8      Vinclozolin                         1.0
                                   [3-(3,5-Dichlorophenyl)-5-ethenyl-5-
                                   methyl-2,4-oxazolidinedione]
                   51235-04-2      Hexazinone                         1.0
                   51338-27-3      Diclofop methyl                     1.0
                                   [2-[4-(2,4-Dichlorophenoxy)-
                                   phenoxy]propanoic acid, methyl ester]
                   51630-58-1      Fenvalerate                          1.0
                                   [4-Chloro-alpha-( 1 -methylethyl)-
                                   benzeneacetic acid cyano(3-
                                   phenoxyphenyl)methyl ester]
                   52645-53-1      Permethrin                          1.0
                                   [3-(2,2-Dichloroethenyl)-2,2-
                                   dimethylcyclopropane carboxylic acid,
                                   (3-phenoxyphenyl)methyl ester]
                   53404-19-6      Bromacil, lithium salt                 1.0
                   	[2,4(lH,3H)-Pyrimidinedione, 5-bromo-6-
                            Toxics Release Inventory Reporting Form and Instructions
                                                                    11-17

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                               Table II. EPCRA Section 313 Chemical List - RY2009
 CAS Number   Chemical Name
De minimis
   % Limit
                 Arranged by CAS Number
                 methyl-3-(l-methylpropyl), lithium salt]
 53404-37-8      2,4-D 2-ethyl-4-methylpentyl          0.1
                 ester
 53404-60-7      Dazomet, sodium salt                 1.0
                 [Tetrahydro-3,5-dimethyl-2H-1,3,5-
                 thiadiazine-2-thione, ion(l-), sodium]
 55290-64-7      Dimethipin                          1.0
                 [2,3 -Dihydro-5,6-dimethyl-1,4-dithiin
                 1,1,4,4-tetraoxide]
 55406-53-6      3-Iodo-2-propynylbutyl              1.0
                 carbamate
 57213-69-1      Triclopyr triethylammonium salt       1.0
 59669-26-0      Thiodicarb                           1.0
 60168-88-9      Fenarimol                           1.0
                 [.alpha.-(2-Chlorophenyl)-.alpha.-(4-
                 chlorophenyl)-5-pyrimidinemethanol]
 60207-90-1      Propiconazole                        1.0
                 [l-[2-(2,4-Dichlorophenyl)-4-propyl-  1,3-
                 dioxolan-2-yl]-methyl-1H-1,2,4,-triazole]
 62476-59-9      Acifluorfen, sodium salt              1.0
                 [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
                 2-nitrobenzoic acid, sodium salt]
 63938-10-3      Chlorotetrafluoroethane               1.0
 64902-72-3      Chlorsulfuron                        1.0
                 [2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
                 triazin-2-yl)amino] carbonyl]
                 benzenesulfonamide]
 64969-34-2      3,3'-Dichlorobenzidine sulfate         0.1
 66441-23-4      Fenoxaprop ethyl                    1.0
                 [2-(4-((6-Chloro-2-
                 benzoxazolylen)oxy)phenoxy)propanoic
                 acid, ethyl ester]
 67485-29-4      Hydramethylnon                     1.0
                 [Tetrahydro-5,5-dimethyl-2(lH)-
                 pyrimidinone[3-[4-
                 (trifluoromethyl)phenyl]-l-[2-[4-
                 (trifluoromethyl)phenyl]ethenyl]-2-
                 propenylidene]hydrazone]
 68085-85-8      Cyhalothrin                         1.0
                 [3-(2-Chloro-3,3,3-trifluoro-1-propenyl)-
                 2,2-dimethylcyclopropanecarboxylic acid
                 cyano(3-phenoxyphenyl) methyl ester]
 68359-37-5      Cyfluthrin                           1.0
                 [3-(2,2-Dichloroethenyl)-2,2-
                 dimethylcyclopropanecarboxylic acid,
                 cyano(4-fluoro-3 -phenoxyphenyl) methyl
                 ester]
 69409-94-5      Fluvalinate                           1.0
                 [N-[2-Chloro-4-
                 (trifluoromethyl)phenyl]DL-valine(+)-
                 cyano(3 -phenoxyphenyl)methyl ester]
 69806-50-4      Fluazifop butyl                      1.0
                 [2-[4-[[5-(Trifluoromethyl)-2-
                 pyridinyl]oxy]phenoxy]propanoic acid,
                 butyl ester]
 71751-41-2      Abarriectiri[AvermectiriBl]           1.0
 72178-02-0      Fomesafen                           1.0
	[5-(2-Chloro-4-(trifluoromethyl)phenoxy)-
CAS Number   Chemical Name
De minimis
   % Limit
                                    Arranged by CAS Number
                                   N-methylsulfonyl)-2-nitrobenzamide]
                   72490-01-8     Fenoxycarb                         1.0
                                   [[2-(4-Phenoxy phenoxy)ethyl]carbamic
                                   acid ethyl ester]
                   74051-80-2     Sethoxydim                         1.0
                                   [2-[l-(Ethoxyimino)butyl]-5-[2-
                                   (ethylthio)propyl] -3 -hydroxyl-2-
                                   cy clohexen-1 -one]
                   76578-14-8     Quizalofop-ethyl                    1.0
                                   [2-[4-[(6-Chloro-2-quinoxarinyl)
                                   oxy]phenoxy]propanoic acid ethyl ester]
                   77501-63-4     Lactofen                            1.0
                                   [Benzoic acid, 5-[2-Chloro-4-
                                   (trifluoromethyl)phenoxy]-2-nitro-, 2-
                                   ethoxy-l-methyl-2-oxoethyl ester]
                   82657-04-3     Bifenthrin                          1.0
                   88671-89-0     Myclobutanil                        1.0
                                   [.alpha.-Butyl-.alpha.-(4-chlorophenyl)-
                                   1H-1,2,4-triazole-1 -propanenitrile]
                   90454-18-5     Dichloro-l,l,2-trifluoroethane         1.0
                   90982-32-4     Chlorimuron ethyl                   1.0
                                   [Ethyl-2-[[[[(4-chloro-6-methoxyprimidin-
                                   2-yl)amino]carbonyl]
                                   amino] sulfonyl]benzoate]
                   101200-48-0    Tribenuron methyl                   1.0
                                   [2-[[[[(4-Methoxy-6-methyl-l,3,5-triazin-
                                   2-yl)methylamino]carbonyl]
                                   amino] sulfonyl]benzoic acid methyl ester]
                   111512-56-2    l,l-Dichloro-l,2,3,3,3-               1.0
                                   pentafluoropropane (HCFC-225eb)
                   111984-09-9    3,3'-Dimethoxybenzidine             0.1
                                   hydrochloride (o-Dianisidine
                                   hydrochloride)
                   127564-92-5    Dichloropentafluoropropane          1.0
                   128903-21-9    2,2-Dichloro-l, 1,1,3,3-               1.0
                                   pentafluoropropane (HCFC-225aa)
                   136013-79-1    1,3-Dichloro-l, 1,2,3,3-               1.0
                                   pentafluoropropane (HCFC-225ea)
                   c.
          Chemical Categories
                   Section 313  requires reporting  on the EPCRA Section 313
                   chemical  categories  listed below,  in  addition to  the  specific
                   EPCRA Section 313 chemicals listed above.

                   The metal compound categories listed below, unless otherwise
                   specified, are defined as including any unique chemical substance
                   that contains the named metal (e.g., antimony, nickel, etc.) as part
                   of that chemical's structure.

                   EPCRA Section 313 chemical categories are subject to the 1% de
                   minimis concentration unless the substance involved meets the
                   definition of an OSHA carcinogen in  which case the 0.1% de
                   minimis concentration applies. The de minimis concentration for
                   each category  is provided in parentheses.   The de  minimis
                   exemption is not available for PBT  chemicals, therefore an
                   asterisk appears where a de minimis limit would otherwise appear.
                            Toxics Release Inventory Reporting Form and Instructions
                                                                    11-18

-------
                             Table II. EPCRA Section 313 Chemical List - RY2009
However, for purposes of the supplier notification requirement only,
such limits are provided in Appendix D.
N010
N020
N040
        Antimony Compounds (1.0)
        Includes any unique chemical substance that contains
        antimony as part of that chemical's infrastructure.

        Arsenic Compounds (inorganic compounds: 0.1;
        organic compounds: 1.0)
        Includes any unique chemical substance that contains
        arsenic as part of that chemical's infrastructure.

        Barium Compounds (1.0)
        Includes any unique chemical substance that contains
        barium as part of that chemical's infrastructure. This
        category does not include:
        Barium sulfate CAS Number 7727-43-7

        Beryllium Compounds (0.1)
        Includes any unique chemical substance that
        contains beryllium as part of that chemical's
        infrastructure.

        Cadmium Compounds (0.1)
        Includes any unique chemical substance that
        contains cadmium as part of that chemical's
        infrastructure.
N084   Chlorophenols (0.1)
N050
N078
N090
N096
N100
                      Where x = 1 to 5

        Chromium Compounds
        (except for chromite ore mined in the Transvaal
        Region of South Africa and the unreacted ore
        component of the chromite ore processing residue
        (COPR). COPR is the solid waste remaining after
        aqueous extraction of oxidized chromite ore that has
        been combined with soda ash and kiln roasted at
        approximately 2,000 deg.F.)
        (chromium VI compounds: 0.1; chromium III
        compounds: 1.0)
        Includes any unique chemical substance that contains
        chromium as part of that chemical 's
        infrastructure.

        Cobalt Compounds (inorganic compounds: 0.1;
        organic compounds: 1.0)
        Includes any unique chemical substance that contains
        cobalt as part of that chemical 's infrastructure.

        Copper Compounds (1.0)
        Includes any unique chemical substance that contains
        copper as part of that chemical's infrastructure. This
        category does not include copper phthalocyanine
        compounds that are substituted with only hydrogen,
        and/or chlorine, and/or bromine.

N106   Cyanide Compounds (1.0)
        X^CN' where X = H+ or any other group where a
        formal dissociation can be made. For example KCN
        or Ca(CN)2.

N120   Diisocyanates (1.0)
        This category includes only those chemicals listed
        below.

        38661-72-2      l,3-Bis(methylisocyanate) -
                       cyclohexane
        10347-54-3      l,4-Bis(methylisocyanate)-
                       cyclohexane
        2556-36-7       1,4-Cyclohexane
                       diisocyanate
        134190-37-7    Diethyldiisocyanatobenzene
        4128-73-8       4,4'-Diisocyanatodiphenyl
                       ether
        75790-87-3      2,4'-Diisocyanatodiphenyl
                       sulfide
        91-93-0         3,3'-Dimethoxybenzidine-
                       4,4'-diisocyanate
        91-97-4         3,3'-Dimethyl-4,4'-
                       diphenylene diisocyanate
        139-25-3        3,3'-Dimethyldiphenyl
                       methane-4,4'-diisocyanate
        822-06-0        Hexamethylene-1,6-
                       diisocyanate
        4098-71-9       Isophorone diisocyanate
        75790-84-0      4-Methyldiphenylmethane-3,4-
                       diisocyanate
        5124-30-1       l,l-Methylenebis(4-
                       isocyanatocyclohexane)
        101-68-8        Methylenebis(phenylisocyanate)
                       (MDI)
        3173-72-6       1,5-Naphthalene
                       diisocyanate
        123-61-5        1,3-Phenylene diisocyanate
        104-49-4        1,4-Phenylene diisocyanate
        9016-87-9       Polymeric diphenylmethane
                       diisocyanate
        16938-22-0      2,2,4-Trimethylhexamethylene
                       diisocyanate
        15646-96-5      2,4,4-Trimethylhexamethylene
                       diisocyanate

N150   Dioxin and Dioxin-Like Compounds
        (Manufacturing; and the processing or otherwise
        use of dioxin and dioxin-like compounds if the
        dioxin and dioxin-like compounds are present as
        contaminants in a chemical and if they were
        created during the manufacturing of that
        chemical.) (*) This category includes only those
        chemicals listed below. [Note: When completing the
        Form R Schedule 1, enter the data for each member of
                          Toxics Release Inventory Reporting Form and Instructions
                                                                                                           11-19

-------
                             Table II. EPCRA Section 313 Chemical List - RY2009
        the category in the order they are listed here (i.e., 1-17).]
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
2,3,7,8-
Tetrachlorodibenzo-p-dioxin
1,2,3,7,8-
Pentachlorodibenzo-p-dioxin
1,2,3,4,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-
Hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-
Hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-
Heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8,9-
Octachlorodibenzo-p-dioxin
2,3,7,8-
Tetrachlorodibenzofuran
1,2,3,7,8-
Pentachlorodibenzofuran
2,3,4,7,8-
Pentachlorodibenzofuran
1,2,3,4,7,8-
Hexachlorod-benzofuran
1,2,3,6,7,8-
Hexachlorodibenzofuran
1,2,3,7,8,9-
Hexachlorodibenzofuran
2,3,4,6,7,8-
Hexachlorodibenzofuran
1,2,3,4,6,7,8-
Heptachlorodibenzofuran
1,2,3,4,7,8,9-
Heptachlorodibenzofuran
1,2,3,4,6,7,8,9-
Octachlorodibenzofuran
                                                             N450
                                                             N458
                                                             N495
                                                             N503
                                                             N511
                                                             N575

                                                             N583
N171   Ethylenebisdithiocarbamic acid, salts and esters
EBDCs) (1.0)
        Includes any unique chemical substance that contains an
        EBDC or an EBDC salt as part of that chemical's
        infrastructure.

N230   Certain Glycol Ethers (1.0)

        R-(OCH2CH2)n-OR'
        where n= 1, 2, or 3
        R = alkyl C7 or less; or
        R = phenyl or alkyl substituted phenyl;
        R' = H, or alkyl C7 or less; or
OR= consisting of carboxylic acid ester, sulfate, phosphate, nitrate,
or sulfonate.

N420   Lead Compounds (*)
        Includes any unique chemical substance that contains
N590
        lead as part of that chemical's infrastructure.

        Manganese Compounds (1.0)
        Includes any unique chemical substance that contains
        manganese as part of that chemical's infrastructure.

        Mercury Compounds (*)
        Includes any unique chemical substance that contains
        mercury as part of that chemical's infrastructure.

        Nickel Compounds (0.1)
        Includes any unique chemical substance that contains
        nickel as part of that chemical's infrastructure.

        Nicotine and salts (1.0)
        Includes any unique chemical substance that contains
        nicotine  or a nicotine salt as part of that chemical's
        infrastructure.

        Nitrate compounds (water dissociable; reportable
        only when in aqueous solution) (1.0)
                                                                                                  H(10-x)
                                                                                 Where x = 1 to 10
        Polybrominated Biphenyls (PBBs) (0.1)

        Polychlorinated alkanes (Ci0 to Ci3) (1.0, except for
        those members of the category that have an average
        chain length of 12 carbons and contain an average
        chlorine content of 60% by weight which are subject
        to the 0.1% de minimis)
where x= 10 to 13;
y = 3 to 12; and
the average chlorine content ranges from 40 C 70% with
the limiting molecular formulas CigH^C^ and
16C112

Polycyclic aromatic compounds (PACs)  (*)
This category includes the chemicals listed below.

56-55-3         Benz(a)anthracene
205-99-2        Benzo(b)fluoranthene
205-82-3        Benzo(j)fluoranthene
207-08-9        Benzo(k)fluoranthene
206-44-0        Benzo(j,k)fluorene
189-55-9        Benzo(r,s,t)pentaphene
218-01-9        Benzo(a)phenanthrene
50-32-8         Benzo(a)pyrene
226-36-8        Dibenz(a,h)acridine
224-42-0        Dibenz(aj)acridine
53-70-3         Dibenzo(a,h)anthracene
194-59-2        7H-Dibenzo(c,g)carbazole
                          Toxics Release Inventory Reporting Form and Instructions
                                               11-20

-------
                             Table II. EPCRA Section 313 Chemical List - RY2009
5385-75-1
192-65-4
189-64-0
191-30-0
57-97-6
193-39-5
56-49-5
3697-24-3
5522-43-0
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7, 12-Dimethylbenz(a)-anthracene
Indeno( 1,2,3 -cd)pyrene
3 -Methy Icholanthrene
5-Methylchrysene
1-Nitropyrene
N725   Selenium Compounds (1.0)
        Includes any  unique  chemical  substance that contains
        selenium as part of that chemical's infrastructure.

N740   Silver Compounds (1.0)
        Includes any unique chemical substance that contains silver
        as part of that chemical's infrastructure.

N746   Strychnine and salts (1.0)
        Includes any  unique  chemical  substance that contains
        strychnine  or a strychnine salt as part of that chemical's
        infrastructure.

N760   Thallium Compounds (1.0)
        Includes any unique chemical substance that contains
        thallium as part of that chemical's infrastructure.

N770   Vanadium Compounds (1.0)
        Includes any  unique  chemical  substance that contains
        vanadium as part of that chemical's
        infrastructure.

N874   Warfarin and salts (1.0)
        Includes any  unique  chemical  substance that contains
        warfarin or a warfarin salt as part of that chemical's
        infrastructure.

N982   Zinc Compounds (1.0)
        Includes any unique chemical substance that contains zinc
        as part of that chemical's infrastructure.
                          Toxics Release Inventory Reporting Form and Instructions                          11-21

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   Table III. State Abbreviations
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern Marianas Islands
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming

MT
NE
NV
NH
NJ
NM
NY
NC
ND
MP
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY

Toxics Release Inventory Reporting Form and Instruction
III-l

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          Table IV. Country Codes
AA
AC
AE

AF
AG
AJ
AL
AM
AN
AO
AR
AS
AT

AU
AV
AY
BA
BB
BC
BD
BE
BF
BG
BH
BK

BL
BM
BN
BO
BP
BR
BS
BT
BU
BV
BX
BY
CA
CB
CD
KE
KG
KN
KQ
KR
Aruba
Antigua and Barbuda
United Arab
Emirates
Afghanistan
Algeria
Azerbaijan
Albania
Armenia
Andorra
Angola
Argentina
Australia
Ashmore and Cartier
Islands
Austria
Anguilla
Antarctica
Bahrain
Barbados
Botswana
Bermuda
Belgium
The Bahamas
Bangladesh
Belize
Bosnia and
Herzegovina
Bolivia
Burma
Benin
Belarus
Solomon Islands
Brazil
Bassas da India
Bhutan
Bulgaria
Bouvet Island
Brunei
Burundi
Canada
Cambodia
Chad
Kenya
Kyrgyzstan
North Korea
Kingman Reef
Kiribati
CE
CF

CG
CH
CI
CJ
CK

CM
CN
CO
CR
CS
CT

CU
CV
CW
CY
DA
DJ
DO
DR

EC
EG
El
EK
EN
ER
ES
ET
EU
EZ
FG
FI
FJ
FK

FO
FP
FR
KS
KT
KU
KZ
LA
Sri Lanka
Congo
(Brazzaville)
Congo (Kinshasa)
China
Chile
Cayman Islands
Cocos (Keeling)
Islands
Cameroon
Comoros
Colombia
Coral Sea Islands
Costa Rica
Central African
Republic
Cuba
Cape Verde
Cook Islands
Cyprus
Denmark
Djibouti
Dominica
Dominican
Republic
Ecuador
Egypt
Ireland
Equatorial Guinea
Estonia
Eritrea
El Salvador
Ethiopia
Europa Island
Czech Republic
French Guiana
Finland
Fiji
Falkland Islands
(Islas Malvinas)
Faroe Islands
French Polynesia
France
South Korea
Christmas Island
Kuwait
Kazakhstan
Laos
FS

GA
GB
GG
GH
GI
GJ
GK
GL
GM
GO
GP
GR
GT
GV
GY
GZ
HA
HK
HM

HO
HR
HU
1C
ID
IM
IN
IO

IP
IR
IS
IT
IV
IZ
JA
JE
JM
JN
JO
JU
LE
LG
LH
LI
LO
French Southern and
Antarctic Lands
The Gambia
Gabon
Georgia
Ghana
Gibraltar
Grenada
Guernsey
Greenland
Germany
Glorioso Islands
Guadeloupe
Greece
Guatemala
Guinea
Guyana
Gaza Strip
Haiti
Hong Kong
Heard Island and
McDonald Islands
Honduras
Croatia
Hungary
Iceland
Indonesia
Isle of Man
India
British Indian Ocean
Territory
Clipperton Island
Iran
Israel
Italy
Cote D'lvoire
Iraq
Japan
Jersey
Jamaica
Jan Mayen
Jordan
Juan de Nova Island
Lebanon
Latvia
Lithuania
Liberia
Slovakia
Toxics Release Inventory Reporting Form and Instructions
IV-1

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                                Table IV. Country Codes
LS
LT
LU
LY
MA
MB
MC
MD
MF
MG
MH
MI
MK
ML
MN
MO
MP
MR
MT
MU
MV
MX
MY
MZ
NC
NE
NF
NG
NH
NI
NL
NO
NP
NR
NS
NT
NU
NZ
PA
PC
PE
Liechtenstein
Lesotho
Luxembourg
Libya
Madagascar
Martinique
Macau
Moldova
Mayotte
Mongolia
Montserrat
Malawi
Macedonia
Mali
Monaco
Morocco
Mauritius
Mauritania
Malta
Oman
Maldives
Mexico
Malaysia
Mozambique
New Caledonia
Niue
Norfolk Island
Niger
Vanuatu
Nigeria
Netherlands
Norway
Nepal
Nauru
Suriname
Netherlands Antilles
Nicaragua
New Zealand
Paraguay
Pitcairn Islands
Peru
PF
PG
PK
PL
PM
PO
PP
PS
PU
QA
RE
RO
RP
RS
RW
SA
SB

SC
SE
SF
SG
SH
SI
SL
SM
SN
SO
SP
ST
SU
sv
sw
sx


SY
SZ
TD

TE
Paracel Islands
Spratly Islands
Pakistan
Poland
Panama
Portugal
Papua New Guinea
Palau
Guinea-Bissau
Qatar
Reunion
Romania
Philippines
Russia
Rwanda
Saudi Arabia
St. Pierre and
Miquelon
St. Kitts and Nevis
Seychelles
South Africa
Senegal
St. Helena
Slovenia
Sierra Leone
San Marino
Singapore
Somalia
Spain
St. Lucia
Sudan
Svalbard
Sweden
South Georgia and
South Sandwich
Islands
Syria
Switzerland
Trinidad and
Tobago
Tromelin Island
TH
TI
TK

TL
TN
TO
TP

TS
TT
TU
TV
TW
TX
TZ
UG
UK
UP
UV
UY
UZ
VC

VE
VI

VM
VT
WA
WE
WF
WI
WS
WZ
YI
YM
ZA
ZI


Thailand
Tajikistan
Turks and Caicos
Islands
Tokelau
Tonga
Togo
Sao Tome and
Principe
Tunisia
East Timor
Turkey
Tuvalu
Taiwan
Turkmenistan
Tanzania
Uganda
United Kingdom
Ukraine
Burkina Faso
Uruguay
Uzbekistan
St. Vincent and the
Grenadines
Venezuela
British Virgin
Islands
Vietnam
Vatican City
Namibia
West Bank
Wallis and Futuna
Western Sahara
Western Samoa
Swaziland
Yugoslavia
Yemen
Zambia
Zimbabwe


IV-2
Toxics Release Inventory Reporting Form and Instructions

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Appendix A.   TRI  Federal Facility  Reporting
Information
Special Instructions for TRI Federal
Facility Reporting


A.1  Why  Do  Federal

Facilities Need to Report?

Executive  Order   13423,  "Strengthening  Federal
Environmental    Energy,    and    Transportation
Management," requires federal agencies to comply
with the Emergency Planning and Community Right-
To-Know Act of  1986 (EPCRA) and the  Pollution
Prevention Act of 1990 (PPA). Federal facilities have
been subject to EPCRA section 313  and PPA since
reporting year 1994. TRI  submissions are due to EPA
on  July 1  of the year  following  each  reporting
(calendar) year. Reporting by the federal facility does
not alter the reporting obligation of on-site contractors.
Contracts entered into after the date of this order for
contractor operation of government-owned facilities or
vehicles require the contractor to  comply  with  the
provisions of this  order with respect to such facilities
or vehicles  to the same extent as the agency  would be
required to  comply if the agency operated facilities or
vehicles.

For more information on Executive Order 13423 please
refer to the implementing  instructions, which can be
found on the TRI home page at http://www.epa.gov/tri


A.2  Identifying Federal

Facility  Reports

Federal facility reports are identified as federal by
several  indicators on the form. The facility name  and
parent company name are critical indicators  and must
be reported as described below.  Another critical
indicator is the federal facility report box, Part I, 4.2c.
Federal facilities only should check this box to indicate
that the report is from a federal agency for a federal
facility; federal facilities should not check the GOCO
box, (Part I, Section 4.2d of the Form R).  Contractors
located at federal facilities  (GOCOs) should check the
GOCO  box (Part I, Section 4.2d of the Form R); they
should not  check the box  4.2c.  Facilities should also
complete the partial or complete facility blocks (Form
R page 2, block 4.2a and 4.2b) as appropriate.  If you
are  a federal facility reporting for the first time, you
should  write "new" in the TRI Facility ID (TRIFID)
box, even if a contractor has reported for your facility
in the past.  The  contractor will retain the original
TRIFID. You will be assigned a new TRIFID the first
time you report.


A.3  The  "Double

Counting"  Problem

As structured, the law and the executive order require
both regulated industries and the federal government to
report TRI data, sometimes for the same site.  In order
to prevent duplicate data  in the TRI database, which
could  result in  "double  counting" data for  some
chemicals and locations, EPA must be able to identify
and distinguish the GOCO  reports submitted by the
federal  contractor from the federal  facility reports
which contain data for the same site.  To accomplish
this, federal facility reports should be accompanied by
either  1) exact copies (paper or electronic) of all
contractor TRI reports, including when  the  totals
reported by the federal facility are greater than that
reported by the contractor(s), or 2)  a cover letter which
includes a list of the facility contractors which submit
TRI reports  to EPA,  identifying  each contractor by
name, TRI technical contact, and TRI facility name and
address. Additionally, federal facilities should check
Form R, Part  I,  Section 4.2c, while  contractors at
federal  facilities should check Form R,  Part I, Section
4.2d.


A.4  Magnetic  Media

Reporting

All  federal  facilities  are  required  to  report  using
Internet reporting.  If the GOCO submits its reports on
magnetic media to EPA and to the federal facility, the
federal  facility  may submit magnetic media copies of
their GOCO TRI reports to  EPA  provided that those
reports  account for all subject activities at the facility.
Magnetic media reports must be  accompanied by a
cover letter which includes:

   •    Required Form R certification statement;
   •  List of the chemicals reported on the federal
     facility's disk; and
   •  List that identifies the contractor(s) [if any] by
     name  and by TRIFID number if they have an
     assigned TRIFID number,  and  the chemicals
     they reported (which are on the  contractors'
     attachment disk(s)).
                   Toxics Release Inventory Reporting Forms and Instructions
                                        A-l

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                                        Appendix A
A.5  How to  Report Your

Facility Name

Facility name is a critical data element.  It is used by
EPA to create the TRI facility ID number (TRIFID),
which is a unique number designed to identify a facility
site.  The facility name and TRIFID number are used
by all TRI data users to link data from a single site
across multiple reporting years.  A federal facility is
assigned a  new TRIFID number when the federal
report is entered into the Toxics Release Inventory
system  for  the first time.  This  TRIFID  number,
generated when the first report is entered into  the
Toxics Release Inventory System, will be included in
future reporting packages sent to the federal facility,
and should be used by the federal facility in all future
reports.

Federal facilities should report their facility  name on
page 1 of the Form Rs (Section 4.1), as  shown in the
following example:

       U.S. DOE Savannah River Site
It is very important that the agency name appear first,
followed by the specific plant or site name.

Federal contractors at GOCO facilities should report
their names as shown in the following example:

       U.S. DOE Savannah River Site -
       Westinghouse Operations.


A.6  How to  Report Your

North American  Industry

Classification System

(NAICS) Code

Federal facilities should report the NAICS code which
most closely represents the activities taking place at the
site. Additional guidance on determining your NAICS
code is provided in the Forms and Instructions booklet.
The  table   on the  next  page  contains  Public
Administration NAICS codes  covering executive,
legislative,  judicial, administrative  and regulatory
activities of  the Federal government.   Government-
owned  and  operated  business  establishments   are
classified in major NAICS groups according  to  the
activity in which they are engaged.  For example, a
Veterans Hospital would be classified in Group 806 -
Hospitals.
                               A.7  How to Report Your

                               "Parent Company" Name

                               Federal facilities should report their parent company
                               name on page  2  of the Form Rs (Section 5.1) by
                               reporting their complete Department or Agency name,
                               as shown in the following example:

                                      U.S. Department of Energy
                               Block  5.2, Parent Company's Dun & Bradstreet
                               Number, should be marked NA.

                               Federal  contractors at GOCO  facilities should not
                               report a federal department or agency name as  their
                               parent  company.   A  federal  name  in the parent
                               company name field will classify the report as federal,
                               and the GOCO may be identified as a non-reporter.


                               A.8  How to Revise Your

                               Data After It Has Been

                               Submitted

                               Any TRI Form R submitter may voluntarily revise their
                               submission if they find errors after their reports  have
                               been sent to EPA. If the revision is to a hardcopy
                               report,  the  facility reporter  should photocopy the
                               original form and use a blue or black pen to mark out
                               the incorrect value and write in the corrected value.
                               The revised report should be submitted to EPA, with an
                               "X"  in the revision block on page 1 of the Form R. If
                               the revision is to a diskette, a new diskette should be
                               submitted, containing  the data  only for the  revised
                               submission, not  all the chemicals originally reported. If
                               a federal facility receives a copy of a revision from a
                               contractor located at the federal facility, the facility
                               should revise the federal report, and submit the revised
                               report to EPA and the appropriate state along with an
                               exact copy  of the contractor's  revision.   The cover
                               letter from the federal facility should indicate that its
                               submission is a revision.


                               A.9  Who Should Sign

                               Federal  Form R Reports?

                               Federal Form R reports should be signed by the senior
                               federal employee on-site. If no federal employee is on-
                               site,  federal Form R reports must be signed by the
                               senior   federal  employee   with   management
                               responsibility for the  site.  Federal Form R reports
                               should be signed by a federal employee.  Contractor
                               employee signatures are not considered valid on federal
                               reports.
A-2
Toxics Release Inventory Reporting Forms and Instructions

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                                        Appendix A
A.10 More  Help  is

Available!

Federal facilities may call the EPA/TRI Information
Center to ask specific questions concerning  how to
submit their Form R report. For contact information,
see the TRI Home Page at http://www.epa.gov/tri/


A.11 North American

Industry Classification

System Codes 921-928

Sector 92 - Public Administration

921    Executive, Legislative, and Other
General Government Support

92111  Executive Offices
92112  Legislative Bodies
92113  Public Finance Activities
92114  Executive and Legislative Offices Combined
92115  American Indian and Alaska Native Tribal
       Governments
92119  General Government, Not Elsewhere
       Classified

922    Justice, Public Order, and Safety
Activities

92211  Courts
92212  Police Protection
92213  Legal Counsel and Prosecution
92214  Correctional Institutions
92215  Parole Offices and Probation Offices
92216  Fire Protection
92219  Other Justice, Public Order and Safety
       Activities

923    Administration  of Human Resource
Programs

92311  Administration of Educational Programs
92312  Administration of Public Health Programs
92313  Administration of Human Resource Programs
       (Except Education, Public Health, and
       Veterans' Affairs Programs)
92314  Administration of Veterans Affairs

924    Administration  of Environmental
Quality Programs

92411  Administration of Air and Water Resource
       and Solid Waste Management Programs
92412  Administration of Conservation Programs
925    Administration of Housing
Programs, Urban Planning, and
Community Development

92511  Administration of Housing Programs
92512  Administration of Urban Planning and
       Community and Rural Development

926    Administration of Economic
Programs

92611  Administration of General Economic
       Programs
92612  Regulation and Administration of
       Transportation Programs
92613  Regulation and Administration of
       Communications, Electric, Gas, and Other
       Utilities
92614  Regulation of Agricultural Marketing and
       Commodities
92615  Regulation, Licensing, and Inspection of
927

92711

928
Affairs
Miscellaneous Commercial Sectors

Space Research and Technology

Space Research and Technology

National Security and International
92811  National Security
92812  International Affairs
                   Toxics Release Inventory Reporting Forms and Instructions
                                       A-3

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Appendix B.  Reporting Codes for EPA Form R
and Instructions for Reporting Metals
B.1 Form  R Part
Revision Codes:

RRl   New Monitoring Data
RR2   New Emission Factor(s)
RR3   New Chemical Concentration Data
RR4   Recalculation(s)
RR5   Other Reason(s)

Withdrawal Codes:
N760  Thallium compounds
N770  Vanadium compounds
N874  Warfarin and salts
N982  Zinc compounds

Section 4. Maximum Amount of the
Toxic Chemical On-Site at Any Time
During the Calendar Year


               Range(pounds)
WT 1 Did not meet the reporting threshold for
manufacturing, processing, or otherwise use
WT2 Did not meet the reporting threshold for number
of employees
WT3 Not in a covered NAICS Code
WO1 Other reason(s)
Section 1.1. CAS Number

EPCRA Section 313 Chemical Category
o */
Codes

NO 1 0 Antimony compounds
N020 Arsenic compounds
N040 Barium compounds
N050 Beryllium compounds
N078 Cadmium compounds
N084 Chlorophenols
N090 Chromium compounds
N096 Cobalt compounds
N100 Copper compounds
N106 Cyanide compounds
N120 Diisocyanates
N150 Dioxin and dioxin-like compounds
N17 lEthylenebisdithiocarbamic
acid, salts and esters (EBDCs)
N230 Certain glycol ethers
N420 Lead compounds
N450 Manganese compounds
N458 Mercury compounds
N495 Nickel compounds
N503 Nicotine and salts
N5 1 1 Nitrate compounds
N575 Polybrominatedbiphenyls(PBBs)
N583 Polychlorinated alkanes
N590 Poly cyclic aromatic compounds
N725 Selenium compounds
N740 Silver compounds
N746 Strychnine and salts

Range Code From To
m n oo
Ul U yy
02 100 999
m i nnn o ooo
UJ 1,UUU y,yyy
04 10,000 99,999
05 100,000 999,999
06 1,000,000 9,999,999
07 10,000,000 49,999,999
08 50,000,000 99,999,999
09 100,000,000 499,999,999
10 500,000,000 999,999,999
11 1 billion more than 1 billion

Section 5. Quantity of the Non-PBT
Chemical Entering Each Environmental
Medium On-site and Section 6.
Transfers of the Toxic Chemical in
Wastes to Off-Site Locations

Total Release or Transfer

Code Range (pounds)
A 1-10
B 11-499
C 500-999

Basis of Estimate

Ml - Estimate is based on continuous monitoring
data or measurements for the EPCRA
section 313 chemical.

M2- Estimate is based on periodic or random
monitoring data or measurements for the
EPCRA section 313 chemical.


                 Toxics Release Inventory Reporting Forms and Instructions
                             B-l

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                                             Appendix B
C-      Estimate is based on mass balance calculations,
        such as calculation of the amount of the EPCRA
        section 313 chemical in streams entering and
        leaving process equipment.

El -     Estimate is based on published emission factors,
        such as those relating release quantity to
        through-put or equipment type (e.g., air emission
        factors).

E2-     Estimate is based on site specific emission
        factors, such as those relating release quantity to
        through-put or equipment type (e.g., air emission
        factors).

O-      Estimate is based on other approaches such as
        engineering calculations (e.g., estimating
        volatilization using published mathematical
        formulas) or best engineering judgment.  This
        would include applying an estimated removal
        efficiency to a waste stream, even if the
        composition of the stream before treatment was
        fully identified through monitoring data.

Section 6.  Transfers of the Toxic Chemical
in Wastes to Off-Site Locations

Type of Waste Disposal/Treatment/Energy
Recovery/Recycling

M10    Storage Only
M20    Solvents/Organics Recovery
M24    Metals Recovery
M26    Other Reuse or Recovery
M28    Acid Regeneration
M40    Solidification/Stabilization
M41    Solidification/Stabilization-Metals and Metal
        Category Compounds only
M50    Incineration/Thermal Treatment
M54    Incineration/Insignificant Fuel Value
M56    Energy Recovery
M61    Wastewater Treatment  (Excluding POTW)
M62    Wastewater Treatment  (Excluding POTW) C
        Metals and Metal Category Compounds only
M64    Other Landfills
M65    RCRA Subtitle C Landfills
M66    Subtitle C Surface Impoundment
M67    Other Surface Impoundments
M69    Other Waste Treatment
M73    Land Treatment
M79    Other Land Disposal
M81    Underground Injection to Class I Wells
M82    Underground Injection to Class II-V Wells
M90    Other Off-Site  Management
M92    Transfer to Waste Broker C Energy Recovery
M93    Transfer to Waste Broker C Recycling
M94    Transfer to Waste Broker C Disposal
                               M95    Transfer to Waste Broker C Waste
                                       Treatment
                               M99    Unknown

                               Section 7A.  On-Site Waste Treatment
                               Methods and Efficiency

                               General Waste Stream

                               A      Gaseous (gases, vapors, airborne
                                       particulates)
                               W      Wastewater (aqueous waste)
                               L      Liquid waste streams (non-aqueous waste)
                               S      Solid waste streams (including sludges and
                                       slurries)

                               Waste Treatment Methods

                               Air Emissions Treatment

                               A01    Flare
                               A02    Condenser
                               A03    Scrubber
                               A04    Absorber
                               A05    Electrostatic Precipitator
                               A06    Mechanical Separation
                               A07    Other Air Emission Treatment

                               Chemical Treatment

                               H040   Incineration-thermal destruction other than
                                       use as a fuel
                               H071   Chemical reduction with or without
                                       precipitation
                               H073   Cyanide destruction with or without
                                       precipitation
                               H075   Chemical oxidation
                               H076   Wet air oxidation
                               H077   Other chemical precipitation with or without
                                       pre-treatment

                               Biological Treatment

                               H081   Biological treatment with or without
                                       precipitation

                               Physical Treatment

                               H082   Adsorption
                               H083   Air or steam stripping
                               H101   Sludge treatment and/or dewatering
                               H103   Absorption
                               Hill   Stabilization or chemical fixation prior to
                                       disposal
                               HI 12   Macro-encapsulation prior to disposal
                               H121   Neutralization
                               HI 22   Evaporation
                               H123   Settling or clarification
                               HI24   Phase separation
                               H129   Other treatment
B-2
Toxics Release Inventory Reporting Forms and Instructions

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                                             Appendix B
Section 7B.  On-Site Energy Recovery
Processes

UOl     Industrial Kiln
U02     Industrial Furnace
U03     Industrial Boiler

Section 7C.  On-Site Recycling Processes

H10     Metal recovery (by retorting, smelting, or
        chemical or physical extraction)
H20     Solvent recovery (including distillation,
        evaporation, fractionation or extraction)
H3 9     Other recovery or reclamation for reuse
        (including acid regeneration or other chemical
        reaction process)


Section 8.10. Source Reduction Activity
Codes
Good Operating Practices

W13    Improved maintenance scheduling, record
        keeping, or procedures
W14    Changed production schedule to minimize
        equipment and feedstock changeovers
W19    Other changes in operating practices

Inventory Control

W21    Instituted procedures to ensure that materials do
        not stay in inventory beyond shelf-life
W22    Began to test outdated material C continue to use
        if still effective
W23    Eliminated shelf-life requirements for stable
        materials
W24    Instituted better labeling procedures
W25    Instituted clearinghouse to exchange materials
        that would otherwise be discarded
W29    Other changes in inventory control

Spill and Leak Prevention

W31    Improved storage or stacking procedures
W32    Improved procedures for loading, unloading, and
        transfer operations
W33    Installed overflow alarms or automatic shut-off
        valves
W3 5    Installed vapor recovery systems
W36    Implemented inspection or monitoring program
        of potential spill or leak sources
W39    Other changes made in spill and leak prevention

Raw Material Modifications

W41    Increased purity of raw materials
W42    Substituted raw materials
W49    Other raw material modifications made
Process Modifications

W51    Instituted recirculation within a process
W52    Modified equipment, layout, or piping
W53    Use of a different process catalyst
W54    Instituted better controls on operating bulk
        containers to minimize discarding of empty
        containers
W55    Changed from small volume containers to
        bulk containers to minimize discarding of
        empty containers
W58    Other process modifications

Cleaning and Degreasing

W59    Modified stripping/cleaning equipment
W60    Changed to mechanical stripping/cleaning
        devices (from solvents or other materials)
W61    Changed to aqueous cleaners (from solvents
        or other materials)
W63    Modified containment procedures for
        cleaning units
W64    Improved draining procedures
W65    Redesigned parts racks to reduce drag out
W66    Modified or installed rinse systems
W67    Improved rinse equipment design
W68    Improved rinse equipment operation
W71    Other cleaning and degreasing
        modifications

Surface Preparation and Finishing

W72    Modified spray systems or equipment
W73    Substituted coating materials used
W74    Improved application techniques
W75    Changed from spray to other system
W78    Other surface preparation and finishing
        modifications

Product Modifications

W81    Changed product specifications
W82    Modified design or composition of products
W83    Modified packaging
W89    Other product modifications

Section 8.10.  Methods Used to Identify
Source Reduction Activities

For each source reduction activity, enter up to three of
the following codes that correspond to the method(s)
which contributed most to the  decision to implement
that activity.

TO 1     Internal Pollution Prevention Opportunity
        Audit(s)
T02     External Pollution Prevention Opportunity
        Audit(s)
T03     Materials Balance Audits
T04     Participative Team Management
                          Toxics Release Inventory Reporting Forms and Instructions
                                          B-3

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                                            Appendix B
T05    Employee Recommendation (independent of a          T08    Federal Government Technical Assistance
       formal company program)                                  Program
T06    Employee Recommendation (under a formal            T09    Trade Association/Industry Technical
       company program)                                        Assistance Program
T07    State Government Technical Assistance Program        T10    Vendor Assistance
                                                        Til    Other
B-4                      Toxics Release Inventory Reporting Forms and Instructions

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                                           Appendix B
B.2  Reporting  the Waste Management of Metals

This appendix outlines how the TRI-ME reporting software restricts reporting for metals when the specific data element or
waste management code is not applicable for a particular chemical. Below is a list of metals divided into four groups along
with charts that help explain where quantities of these chemicals can and can not be reported on the Form R using TRI-ME.
In addition, there are charts that explain restrictions on reporting waste management codes for the toxic chemicals in each of
the four groups.  This appendix only shows where reporting is restricted in TRI-ME, it does not indicate every situation where
a metal should not be reported in a specific section of the form. For example, TRI-ME does not restrict the reporting of most
individually-listed metal compounds as used for energy recovery (Sections 8.2 and 8.3) even though some of these chemicals
do not have a heat value greater that 5000 British thermal units (Btu) and, thus, can not be combusted for energy recovery. It
is left to the facility to decide which of these toxic chemicals can be used for energy recovery. If you are not using TRI-ME
this appendix can serve as a guide to help you understand where it is not appropriate to report certain quantities of toxic
chemicals or waste management codes on your Form R.
Parent Metals:

Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Metal Compound
Categories:

Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chromium Compounds
Cobalt Compounds
Copper Compounds
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Vanadium Compounds
Zinc Compounds
Metals with
Qualifiers:

Aluminum (fume or dust)
Vanadium (except when
in an alloy)
Zinc (fume or dust)

Individually-Listed
Metal Compounds:

Bis(tributylin) oxide
Triphenyltin hydroxide
Triphenyltin chloride
Molybdenum trioxide
Thorium dioxide
Asbestos (friable)
Aluminum oxide (fibrous
forms)
Tributyltin fluoride
Tributyltin
methacrylate
Titanium
tetrachloride
Boron trifluoride
Metiram
Boron trichloride
Zineb
Maneb
Fenbutatin oxide
Iron pentacarbonyl
Ferbam
C.I. Direct Brown
95
Osmium tetroxide
Aluminum
phosphide
C.I. Direct Blue
218
Sections 5.3 - Discharges to Water and 6.1 - Transfers to POTWs

The following chart indicates which metals can be reported as released to water in Section 5.3 or to POT W' s in Section 6.1.
Only zinc (fume or dust) and aluminum (fume or dust) are not reported in these sections because the fume or dust form of a
toxic chemical can not exist in water.
Form R Section in
Part II
Section 5. 3 -
Discharges to
receiving streams or
water bodies
Section 6.1-
Discharges to
POTWs
Parent Metals
All
All
Metal Category
Compounds
All
All
Metals with
Qualifiers
Vanadium (except
when contained in an
alloy)
Vanadium (except
when contained in an
alloy)
Individually-listed
Metal Compounds
All except Asbestos
All except Asbestos
                         Toxics Release Inventory Reporting Forms and Instructions
                                                                     B-5

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                                             Appendix B
Section 6.2.  Transfers to Other Off-Site Locations

Any toxic chemical may be reported in Section 6.2.  However, TRI-ME will not allow certain M codes to be used when
reporting metals.  The chart below indicates which M codes can be reported in Section 6.2 for the four groups of metals.
Note that all disposal M codes other than M41 and M62 can be used for all toxic chemicals.  Code M24 is only made
available for the four groups of metals.
Waste Management Code for
Section 6.2
M41 and M62 (disposal codes-for
metals only)
M56 and M92 (energy recovery
codes)
M20 and M28 (recycling codes)
M24, M26 and M93 (recycling
codes)
M40, M50, M54, (treatment codes)
M61, M69, M95 (treatment codes)
Parent
Metals
All
None
None
All
None
Barium2
Metal Category
Compounds
All
None
None
All
None
Barium
Compounds2
Metals with
Qualifiers
Vanadium (except
when contained in an
alloy)
None
None
All
All except Vanadium
(except when
contained in an alloy)
Same as above
Individually-
listed Metal
Compounds
All except
Asbestos
All except
Asbestos1
All
All
All
All
Section 7A.  On-site Waste Treatment Methods and Efficiency

TRI-ME allows any toxic chemical to be reported in Section 7A, however, it limits reporting in two ways. First, TRI-ME
limits the treatment codes that can be reported based on the General Waste Stream Code selected.  If a TRI-ME user selects
General Waste Stream code "A - Gaseous", all Waste Treatment Codes are made available. However, if a user selects from
the remaining three General Waste Stream Codes (W - Wastewater, L - Liquid waste streams, or S - Solid waste streams), the
"Air Emissions Treatment" Waste Treatment Codes are not made available. Second, the software restricts reporting for
certain toxic chemicals with qualifiers. When reporting zinc (fume or dust) or aluminum (fume or dust) TRI-ME will not
allow the user to select General Waste Stream Codes W-Wastewater and L-Liquid waste streams because the fume or dust
form of a toxic chemical can not exist in a liquid or water waste. For asbestos (friable) only S - Solid or A - Gaseous can be
selected. When reporting hydrochloric acid (acid aerosols) or sulfuric acid (acid aerosols) only A - Gaseous can be selected.
Crosswalk for Section 7 A, Column B. Waste Treatment Method (s) Sequence
Air Emissions Treatment (applicable to gaseous waste streams only)
(No change — same as previous codes)
A01
A02
A03
A04
A05
A06
A07
Flare
Condenser
Scrubber
Absorber
Electrostatic Precipitator
Mechanical Separation
Other Air Emission Treatment














B-6
Toxics Release Inventory Reporting Forms and Instructions

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                  Appendix B
Biological Treatment:
Previous Codes
Bll
B21
B31
B99
Aerobic
Anaerobic
Facultative
Other Biological
Treatment
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H081
H081
H081
H081
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Biological treatment with or without precipitation
Chemical Treatment:
Previous Codes
C01
C02
C09
Cll
C21
C31
C41
C42
C43
C44
C45
C46
C99
Chemical Precipitation B
Lime or Sodium Hydroxide
Chemical Precipitation B
Sulfide
Chemical Precipitation B
Other
Neutralization
Chromium Reduction
Complexed Metals
Treatment (other than pH
adjustment)
Cyanide Oxidation B
Alkaline Chlorination
Cyanide Oxidation B
Electrochemical
Cyanide Oxidation B Other
General Oxidation
(including Disinfection) B
Chlorination
General Oxidation
(including Disinfection) B
Ozonation
General Oxidation
(including Disinfection) B
Other
Other Chemical Treatment
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H071
H071
H077
H121
H071
H129
H073
H073
H073
H075
H075
H075
H129
Chemical reduction with or without precipitation
Chemical reduction with or without precipitation
Other chemical precipitation with or without pre-
treatment
Neutralization
Chemical reduction with or without precipitation
Other treatment
Cyanide destruction with or without precipitation
Cyanide destruction with or without precipitation
Cyanide destruction with or without precipitation
Chemical oxidation
Chemical oxidation
Chemical oxidation
Other treatment
Toxics Release Inventory Reporting Forms and Instructions
B-7

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                                          Appendix B
Chemical Treatment:
Previous Codes
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
Incineration/Thermal Treatment: (Note: Only report combustion for the purposes of incineration/thermal
treatment in Section 7 A. If the method involves combustion for the purposes of energy recover, report as UO 1 ,
U02, or U03 in Section 7B . If the method involves combustion for the purposes of materials recovery, report as
H39 in Section 7C.)
F01
Fll
F19
F31
F41
F42
F51
F61
F71
F81
F82
F83
F99
Liquid Injection
Rotary Kiln with Liquid
Injection Unit
Other Rotary Kiln
Two Stage
Fixed Hearth
Multiple Hearth
Fluidized Bed
Infra-Red
Fume/Vapor
Pyrolytic destructor
Wet air oxidation
Thermal Drying/Dewatering
Other Incineration/Thermal
Treatment
H040
H040
H040
H040
H040
H040
H040
H040
H040
H040
H076
H122
H040
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Incineration B thermal destruction other than use as a
fuel
Wet air oxidation
Evaporation
Incineration B thermal destruction other than use as a
fuel
Physical Treatment:
Previous Codes
P01
P09
Pll
P12
P13
P14
P15
P16
P17
Equalization
Other blending
Settling/clarification
Filtration
Sludge dewatering (non-thermal)
Air flotation
Oil skimming
Emulsion breaking B thermal
Emulsion breaking B chemical
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H129
H129
H123
H123
H101
H124
H124
H124
H124
Other treatment
other treatment
Settling or clarification
Settling or clarification
Sludge treatment and/or dewatering
Phase separation
Phase separation
Phase separation
Phase separation
B-8
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                                           Appendix B
Physical Treatment:
Previous Codes
P18
P19
P21
P22
P23
P29
P31
P41
P42
P49
P51
P61
P99
Emulsion breaking B other
Other liquid phase separation
Adsorption B Carbon
Adsorption B Ion exchange (other
than for recovery/reuse)
Adsorption B Resin
Adsorption B Other
Reverse Osmosis (other than for
recover/reuse)
Stripping B Air
Stripping B Steam
Stripping B Other
Acid Leaching (other than for
recovery/reuse)
Solvent Extraction (other than
recovery/reuse)
Other Physical Treatment
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
H124
H124
H082
H082
H082
H082
H129
H083
H083
H083
H129
H129
H129
Phase separation
Phase separation
Adsorption
Adsorption
Adsorption
Adsorption
Other treatment
Air or steam stripping
Air or steam stripping
Air or steam stripping
Other treatment
Other treatment
Other treatment
Solidification/Stabilization:
Previous Codes
G01
G09
Gil
G20
G99
Cement processes
(including silicates)
Other Pozzolonic
Processes (including
silicates)
Asphaltic Techniques
Thermoplastic
Techniques
Other Solidification
Processes
New Codes (adapted from RCRA Hazardous Waste
Management Codes)
Hill
Hill
Hill
Hill
Hill
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Stabilization or chemical fixation prior to
disposal
Section 7B.  On-site Energy Recovery Processes

The chart below indicates which energy recovery codes can be reported in TRI-ME in Section 7B for the four groups of
metals.
Energy Recovery Code for Section
7B
U01,U02,U03
Parent
Metals
None
Metal
Category
Compounds
None
Metals with
Qualifiers
None
Individually-
listed Metal
Compounds
All except
Asbestos1
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                                          Appendix B
Section 7C. On-site Recycling Processes

Any chemical can be reported in Section 1C. However, certain waste management codes should not be reported for certain
toxic chemicals. The chart below indicates which codes can be reported in Section 7C when using TRI-ME.
Recycling Code for Section 7C
H10(this code is for metals only
H20
H39
Parent
Metals
All
None
All
Metal Category
Compounds
All
None
All
Metals with
Qualifiers
All
None
All
Individually-
listed Metal
Compounds
All
All
All
Crosswalk for Section 7C. On-site Recycling Processes
Previous Codes
Rll
R12
R13
R14
R19
R21
R22
R23
R24
R26
R27
Solvents/Organics Recovery B
Batch Still Distillation
Solvents/Organics Recovery B
Thin-Film Evaporation
Solvents/Organics Recovery B
Fractionation
Solvents/Organics Recovery B
Solvent Extraction
Solvents/Organics Recovery B
Other
Metals Recovery B
Electrolytic
Metals Recovery B Ion
Exchange
Metals Recovery B Acid
Leaching
Metals Recovery B Reverse
Osmosis
Metals Recovery B Solvent
Extraction
Metals Recovery B High
Temperature
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H20
H20
H20
H20
H20
H10
H10
H10
H10
H10
H10
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Solvent Recovery (including distillation, evaporation,
fractionation or extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
B-10
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                                                Appendix B
Previous Codes
R28
R29
R30
R40
R99
Metals Recovery B Retorting
Metals Recovery B Secondary
Smelting
Metals Recovery B Other
Acid Regeneration
Other Reuse or Recovery
New Codes (adapted from RCRA Hazardous Waste Management
Codes)
H10
H10
H10
H39
H39
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Metal Recovery (by retorting, smelting, or chemical or physical
extraction)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Other recovery or reclamation for reuse (including acid
regeneration or other chemical reaction process)
Section 8.  Source Reduction and Recycling Activities

The chart below indicates which metals can be reported in Sections 8.2,8.3,8.6 and 8.7 of the Form R when using TRI-ME.
Note that all toxic chemicals can be reported in Sections 8.1, 8.4, 8.5 and 8.8.
Waste Management Activity
Quantity used for energy recovery
on site and off site (Sections 8.2
and 8.3)
Quantity treated for destruction on
site and off site (Sections 8.6 and
8.7)
Parent
Metals
None
None
except
Barium2
Metal Category
Compounds
None
None except
Barium
Compounds2
Metals with
Qualifiers
None
All except
Vanadium
(except when
contained in an
alloy)
Individually-
listed Metal
Compounds
All except
Asbestos2
All
1 Although TRI-ME does not restrict reporting of most individually-listed metal compounds as transferred off site for
energy recovery, only chemicals with a heat value greater than 5000 British thermal units that are combusted in a device
that is an industrial furnace or boiler (40 CFR Section 372.3) should be reported as used for energy recovery.

2 The toxic chemical category barium compounds  (N040) does not include barium sulfate. Because barium sulfate is not a
listed toxic chemical, the conversion in a waste stream of barium or barium compound to barium sulfate is considered
treatment for destruction (40 CFR Section 372.3).
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Appendix C.   Facility  Data Profiles and  Common
Errors  in  Completing  Form R Reports  and Form A
Certification Statements
EPA wishes to ensure that facilities submit all required TRI
chemical  submissions in a  timely  manner  so  that the
information may be included in its national database, National
Analysis (formerly called the public Data Release (PDR)), and
other information products. Moreover, EPA seeks to ensure
that all submitted data are complete and accurate.  This
appendix provides an overview of the Facility Data Profile
(FDP), an important communication  tool  that EPA uses to
ensure consistent, complete, and accurate  submissions from
reporting facilities.  This appendix  also  provides  specific
guidance to avoid common errors in completing Form Rs and
Form A Certification Statements, including errors in threshold
determination, misapplication of exemptions, and activities
involving a reportable chemical, any of which may result in the
erroneous non-reporting of a chemical.
C.1   Facility Data Profile

(FDP)

FDPs are made available by the TRI Data Processing Center
to a reporting facility in response to any submission the TRI
Data Processing Center receives. You may review your FDP
on the Internet at http://www.triefdp.org. It is very important
that you review your FDP. If the Technical Contact provided
an email address in the Form R/Form A, they will receive a
real-time email notifying them when their FDP has been
updated and posted to the FDP Web site. A submission can
include an  original or revised Form R  or Form A, or
corrections included in a response to a previous FDP.  The
FDP serves two primary purposes.  First, EPA wants to give
the reporting facility the opportunity to confirm that the TRI
Data Processing Center has entered its data correctly into
EPA's national computer system i.e. the TRI Data Processing
Center  echoes back the information that  it  has received.
Second, if the TRI Data Processing Center identifies potential
errors in the forms a facility has submitted, the FDP indicates
what these errors are and requests that the facility provide EPA
with corrections.  The FDP does  not serve as a means to
withdraw a Form R and/or Form A. For additional information
regarding withdrawal procedures  see Section A.5 of this
document or go to http://www.epa.gov/tri.  If you have
questions regarding your FDP, please  send an email to
tridpc@epacdx.net or call,(703) 227-7644. Facilities that send
corrections in response to their FDPs are encouraged to submit
a revision using CDX.  For additional instructions regarding
your FDP, please refer to your FDP.
An FDP is comprised of the following sections:

    •   Facility Information.  This  section displays  all
       facility-specific  data,  including  TRI   Facility
       Identification  (TRIFID),  facility  name,  facility
       address, facility  mailing address, relevant permits
       (e.g., RCRA, NPDES, and UIC), North American
       Industry Classification System code (NAICS), and
       other  facility  data. Errors  related  to  facility
       information will be marked in this section.

    •   Instructions Page. This page provides instructions
       on how to review and respond to the FDP.

    •   Certification Statement Signature Page. This page
       provides the Certification Statement to be signed by a
       facility owner/operator or senior management official
       if using the FDP to make a revision.

    •   Chemical Report Summary. This section lists all
       chemicals reported by the facility for each reporting
       year covered by the FDP. For example, if the FDP is
       responding to five original chemical submissions for
       Reporting Year 2009 and revisions to one chemical
       for Reporting Year 2007, a list of all chemicals for
       both years will appear.

    •   Errors/Alerts Identified  In  This  Report:  Non-
       Technical   Data Changes (NDC), Notices  of
       Technical Errors (NOTE), Notices of Significant
       Error (NOSE), and Data Quality Alerts  (DQA).
       FDPs identify three different types of errors: NDCs,
       NOTEs and NOSEs and one type of alert called Data
       Quality Alert (DQA). See explanations in section B.
    •   Error Summary Page. The Error Summary Page
       provides facilities an error/alert count for each
       chemical submission.

    •   Chemical  Reports.   All recently  submitted and
       processed Form  R or Form A data (i.e., chemical
       specific data) are displayed in the chemical reports
       under the appropriate facility or subordinate facility
       names. The FDP displays facsimiles for chemical
       reports for submissions received during the current
       calendar year and revisions or responses to FDPs
       only.  For example,  if a facility originally reported
       five  chemicals  for Reporting  Year  2009,  and
       subsequently revises only one chemical submission,
       the facility will receive an FDP for Reporting Year
       2009 with only the revised chemical included in the
       Chemical Reports section. Hence there may be fewer
       chemical reports than chemicals  listed  in the
       Chemical Summary  section.  If only facility level
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                                                Appendix C
       changes have occurred (i.e., Part I of the Form R or
       A), this section is not provided.


C.2 Levels of  Errors

Identified  in  FDPs:  Notice of

Non-Technical  Data  Change

(NDC),  Notice of Technical

Errors (NOTE),  Notice  of

Significant Errors (NOSE),

Notice of Noncompliance

(NON)
FDP Error Reporting.  In addition to  echoing back  the
information a facility has submitted, FDPs are used to identify
potential errors  and provide Data Quality  Alerts, as well as
indicate where  the TPJ Data Processing  Center has made
minor clerical  changes  to submissions.    As submission
information is entered into EPA's national database, a series of
automated data quality checks are performed.  The data quality
checks are useful to identify potential errors with certain data
fields such as TPJ Facility Identification, facility name, county
spelling, as well as to perform validation checks to ensure
consistency among data elements  within a given Form R or
Form A. These data quality checks, however, cannot detect
whether release, transfer, or waste management quantities were
calculated or entered accurately. Within a FDP notice, there
may be up to three different types of errors identified.

TRI-MEweb Error Reporting.   One of  the advantages of
using the online electronic TRI-MEweb reporting system is that
it will notify submitters of several  classes of common errors,
decreasing the potential  for reporting errors on the initial
submission that will have  to be corrected later.

First, a Non-Technical Data Change (NDC) notifies you of
simple, clerical errors that the TPJ Data Processing Center has
corrected for you. It is not necessary to respond to a NDC.
The TRI Data Processing Center will correct simple, clerical
errors that are not technical or scientific - a  "non-technical
data change."  For example, if a facility transposes CAS
numbers (e.g., the submitter lists 7623-00-0 for sodium nitrite
instead of 7632-00-0), the TPJ Data Processing Center will
correct this clerical error and display the correct information
on the facility's FDP. If a facility lists a specific glycol ethers
subcategory, the TPJ Data Processing Center will replace this
subcategory with the reportable name Acertain glycol ethers."
The messages used  on FDPs to  report non-technical data
changes are shown at the end of this appendix under  the
heading AE. Messages Used to Report Notices of Technical
Errors (NOTEs) and Non-technical Data Changes (NDCs)."
                               Second, a Notice of Technical Error (NOTE) highlights
                               inconsistencies or miscalculations that may distort  your
                               facility's information in EPA's public data products or  skew
                               analyses. Incomplete addresses, no technical or public contact
                               provided, missing or invalid NAICS codes, or the use of range
                               codes to report PBT chemical releases are all examples of
                               technical errors.  You should respond to NOTEs as soon as
                               possible.  These types of errors require that the reporting
                               facility make corrections on its FDP (or provide the TPJ Data
                               Processing Center with a brief explanation why they do not
                               believe that it is an error) or submit a revised Form R or Form
                               A.  Depending upon when your changes are received,  there
                               may or may not be sufficient time to incorporate them into
                               EPA's database in time for public data release. Technical
                               errors do not prevent submissions from being entered into the
                               data management system, but  indicate inconsistencies  or
                               miscalculations in the submitted form. These errors can distort
                               public information products and skew any analyses if not
                               corrected. The messages used on FDPs to report NOTEs are
                               shownbelow at the end of this appendix under the heading "D.
                                Messages Used  to Report Notices of Technical Errors
                               (NOTEs) and Non-technical Data Changes (NDCs)."

                               Third, more serious errors are classified as Notices  of
                               Significant Errors (NOSE). The FDP contains the Notice of
                               Significant Error if applicable. Significant errors prevent
                               submissions from being entered into the TRI Data Processing
                               Center data management system or do not allow the TPJ Data
                               Processing Center to verify the authenticity of the submission.
                               Invalid forms, missing pages, no certification signature, no
                               chemical name or CAS number are examples of significant
                               errors. These types of errors require that the reporting facility
                               make corrections on their FDP, submit a revised Form R or
                               Form A, or provide the TRI Data Processing Center with a
                               brief explanation why they do not believe that it is an error. A
                               facility must respond to a Notice of Significant Error within 21
                               days of receipt. Failure to respond within the initial 21 day
                               requirement could result in the issuance of a Notice  of
                               Noncompliance (NON). A Notice of Noncompliance is not
                               included in a FDP and is mailed separately.

                               The Agency will issue a Notice of Noncompliance (NON) to
                               a facility for failure to respond to a Notice of Significant Error
                               (NOSE) within the required  period.  A NON will require a
                               facility to take the corrective action noted in the NOSE within
                               30 days and respond to the Agency that corrective action has
                               been taken. If a facility fails to respond to the NON within the
                               required time period, the Agency may take further action.

                               Facilities must keep copies, for three years, of submitted Form
                               R reports and Form A certifications and all documentation
                               used to complete their submissions. This documentation
                               should include calculations for threshold determinations, the
                               basis of exemptions applied, and the estimation techniques and
                               data used for all quantities reported on the Form R and Form
                               A.

                               For the first time beginning with RY 2004, TRI will provide
                               Data Quality Alerts (DQA).  The DQA informs facilities of
C-2
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                                               Appendix C
possible reporting issues, such as a large percentage change in
reported amounts of the same chemical between years.  It is
offered to assist facilities in ensuring accurate reporting.
C.3  Common  Errors  in

Completing  Form  R Reports

and  Form  A  Certification

Statements,  including

Reporting  Determination

Errors

General Considerations

    •   Lack of signed  Certification Statement.  If you
        choose not to send  your TRI submissions via the
        paperless CDX process, you must sign Part I, Section
        3 of your hard copy submission.  Although EPA
        accepts paper submissions, EPA strongly encourages
        you to send your submission via CDX.

    •   Incomplete Forms.  A complete Form R report for a
        single EPCRA  section  313 chemical  or  single
        EPCRA section 313 chemical category consists of
        five pages stapled together.  By using TRI-MEweb
        and CDX, errors such as this would not occur. Each
        chemical submission must have its own page one.
        EPA cannot  enter into the  database  data from a
        package that contains only one page 1, but several
        page 2s, 3s, 4s, and/or 5s.  Suchforms are considered
        incomplete submissions.

Threshold Determinations

    •   Calculating  threshold  determinations. Annual
        quantities manufactured,  processed,  or otherwise
        used for section 313 chemicals must be calculated,
        not surmised. The  assumption that thresholds are
        exceeded commonly leads to error.
    •   Misclassification of EPCRA section 313 chemical
        activity.  Failure to correctly classify an EPCRA
        section 313  chemical activity may result in an
        incorrect threshold determination.  As a result, a
        facility may fail to submit the required Form R.
    •   EPCRA section 313 chemical activity overlooked.
        Many facilities believe that because the section 313
        reporting requirement pertains to manufacturers, only
        the use of  EPCRA  section 313 chemicals in
        manufacturing processes  must be examined. Any
        activity  involving  the manufacture,  process, or
        otherwise use of an EPCRA section 313 chemical or
        chemical category  must be  included  in  threshold
        determinations. Commonly  overlooked  activities
       include importation of chemicals, generation of waste
       byproducts, processing of naturally occurring metals
       and metal category compounds in ore, manufacturing
       and processing intermediates, the use of chemicals
       for cleaning of equipment, and the generation of
       byproducts during combustion of coal and/or oil.
       Facilities should take a  systematic approach to
       identify  all  chemicals  and  mixtures  used  in
       production and non-production capacities, including
       catalysts, well treatment chemicals, and wastewater
       treatment chemicals.

       Considering EPCRA section 313 chemicals in
       mixtures and other trade name products. EPCRA
       section  313   chemicals  contained in  mixtures
       (including ores and stainless steel alloys) and other
       trade name products must be factored into threshold
       determinations  and  release  and  other  waste
       management determinations, provided  that the de
       minimis exemption  cannot  be taken.  When the
       EPCRA section 313 chemical being reported  is a
       component in a mixture or other trade name product,
       report only the weight of the EPCRA section  313
       chemical in the mixture. Refer to Section B.4b of this
       document to calculate the weight  of an EPCRA
       section 313 chemical in a mixture or other trade name
       product.
       Overlooking    manufacturing.    Coincidental
       manufacturing must not be overlooked. If coal and/or
       fuel oil and other raw materials that contain EPCRA
       section 313 chemicals are used in boilers/burners,
       there is a potential for the coincidental manufacture
       of EPCRA section 313 chemicals such as sulfuric
       acid (acid aerosols),  hydrochloric   acid  (acid
       aerosols), hydrogen  fluoride, and metal category
       compounds. Additionally, manufacturing of EPCRA
       section 313 chemicals during waste treatment is
       commonly overlooked. For example, the treatment of
       nitric acid may result in the manufacturing of a
       reportable chemical (nitrate compounds).
Container Residue
       Overlooking container residue. Container residue
       must not be disregarded in release and other waste
       management calculations.  Even a "RCRA empty"
       drum is expected to contain a residue and it must be
       considered for TRI reporting.  Additionally, on-site
       drum rinsing and disposal of the rinsate will result in
       a release and other waste management activity. Refer
       to   Estimating  Releases  and Waste Treatment
       Efficiencies for Toxic Chemical Reporting Forms.
                          Toxics Release Inventory Reporting Forms and Instructions
                                              C-3

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                                                  Appendix C
Part I. Facility Identification Information

Section 1. Reporting Year

    •   Invalid Forms.  The correct version of the form for
        the reporting year in question must be used.  For
        example,  forms provided  for  reporting  years
        1987-1990 must not be used to report data for
        reporting  years  1991-1995. Form Rs  provided for
        reporting years 1991-1995 mustnotbe used to report
        data for years 1996 and later

Section 2. Trade Secret Information
                                          -   Incomplete off-site and POTW information
                                              (e.g., missing city name)
                                 If amounts are reported in units other than pounds (e.g., metric
                                 units) or with  exponential numbers, EPA may require  a
                                 revision of the Form R/Form A submitted. The exception is
                                 for the reporting of dioxin and dioxin-like compounds where
                                 the amounts are reported in grams.
    •   Incorrect completion of trade secret information.
        The responses to trade secret questions in Part I
        Section 2 and Part II Section 1.3 of FormR/Form A
        must be  consistent.  If trade secrecy is indicated, a
        sanitized Form  R/Form  A and  two trade secret
        substantiations (one sanitized) must be submitted in
        the  same package as the unsanitized trade secret
        Form R/Form A. Part II Section 1.3 should be blank
        if no trade secret claim is being made. Also, if you
        indicate  in  Part I,  Section 2.1  that you are not
        claiming trade secret information, leave Part I, 2.2
        blank.

Section 3.  Certification

    •   Missing certification signature.   If you  are
        submitting your Form R and/or Form A by hardcopy,
        an original  certification signature must appear  on
        page 1 of every Form R and/or Form A submitted to
        EPA.  If you are submitting your Form R and/or
        Form A via TRI-MEweb  and  CDX,  you must
        electronically sign the submission before it can be
        loaded into the TRI database, Uncertified electronic
        submissions  will not be  accepted and result in a
        Notice of Significant Error  (NOSE)  if they remain
        uncertified after the July 1st reporting deadline.

Section 4.  Facility Identification

    •   Questionable entries. Incorrect entries may require
        corrections to be made by the facility. The use of the
        TRI-MEweb  software prevents  most errors from
        occurring.  Questionable entries may include:
             Missing or incorrect street address;
             Missing or incorrect ZIP codes;
             Missing County names;
             Invalid SIC codes;
             Missing or invalid Dun & Bradstreet
             numbers;
         -   Missing or invalid RCRA, NPDES, or UIC
             numbers; and
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                                                  Appendix C
Part II. Chemical-Specific Information

Section 1.  Toxic Chemical Identity

    •   Reporting  chemical  abstract  service  (CAS)
        registry numbers in Section 1.1. Beginning with
        the   1991   reporting  year,   EPA has  assigned
        alphanumeric category codes to the twenty chemical
        categories for the purposes of reporting the  CAS
        number field in Section  1.1. When completing a
        Form R for a chemical category, the appropriate code
        for that category  must be provided in Section 1.1.
        The CAS numbers are listed in Table II: "Section 313
        Toxic Chemical List," and if needed, the category
        codes are listed in Appendix B: "Reporting Codes for
        EPA Form  R." Category guidance documents are
        listed in the Chemical  and Industry Guidance
        Documents section in this document.
    •   Failure to check for synonyms. Some reportable
        chemicals  (especially glycol ethers  and toluene
        diisocyanates) have many synonyms that do not
        readily imply they are in the category. For example,
        benzene,!,3-diisocyanatomethyl may not be readily
        recognized as toluene diisocyanate (mixed isomers).
    •   Invalid chemical identification in Section 1.2. The
        CAS number and the chemical name reported here
        must exactly match the listed official EPCRA section
        313 CAS number and EPCRA section 313 chemical
        name.
    •   Failure  to consider an EPCRA section  313
        chemical qualifier. Only EPCRA  section  313
        chemicals in the form specified in the qualifier
        require reporting  under section 313 and should  be
        reported on Form R with the appropriate qualifier in
        parentheses. For example, isopropyl alcohol is listed
        on the EPCRA section 313 chemical list with the
        qualifier manufacturing-  strong  acid process,  no
        supplier notification. Thus, the ONLY facilities that
        should report this EPCRA section 313 chemical are
        those that manufacture  isopropyl alcohol by the
        strong acid process.
    •   Generic chemical name in Section 1.3. A generic
        chemical name should only be provided if the section
        313 chemical identity is claimed as a trade secret.

Section 2.  Mixture Component Identity

    •   Identifying chemicals used in mixtures. Facilities
        should carefully review the most recent MSDS  or
        supplier notification for every mixture brought on-
        site to identify all  section 313  chemicals used during
        a reporting year.  Although some mixtures may not
        have MSDSs, the  best readily available information
        should be used to determine the presence of EPCRA
        section 313 chemicals in ores and alloys.
    •   Mixture names in Section 2.1. Mixture names are to
        be entered here only if the supplier is claiming the
        identity of the EPCRA section 313 chemical a trade
        secret and that is the sole  identification. Mixture
        names that include the name or CAS number of one
        or more EPCRA section 313 chemicals are not valid
        uses of the mixture name field.

Section 3.  Activities and Uses of the Toxic
Chemical at the Facility

    •   Reporting EPCRA section 313 chemical activity.
        EPCRA section 313 chemical activity is commonly
        overlooked or misclassified. Any activity involving
        the manufacture, process, or otherwise use of an
        EPCRA section 313 chemical must be examined. For
        example, waste treatment operations otherwise use
        EPCRA section 313 chemicals to treat waste streams
        and  may coincidentally manufacture an additional
        EPCRA  section 313 chemical as a result of the
        treatment reaction. Such activity must be considered.
        Further, EPCRA section 313 chemical activity must
        be correctly  classified as either "manufactured,"
        "processed," or "otherwise used."
    •   Section 3.1 Manufacture means to produce, prepare,
        compound,  or  import  an  EPCRA  section 313
        chemical.
    •   Section 3.2     Process means the preparation of
        an  EPCRA  section  313  chemical  after  its
        manufacture,   which   usually    includes   the
        incorporation of the EPCRA section 313  chemical
        into the final product, for distribution in commerce.
    •   Section 3.3     Otherwise use encompasses any use
        of an EPCRA section 313 chemical that does not fall
        under the terms "manufacture" or  "process," and
        includes  treatment  for  destruction,  stabilization
        (without subsequent  distribution in commerce),
        disposal, and other use of an EPCRA section 313
        chemical, including an EPCRA section 313 chemical
        contained in a mixture or other trade name product.
        Otherwise use of an EPCRA section 313  chemical
        does  not include disposal, stabilization (without
        subsequent distribution in commerce), or treatment
        for destruction unless:
        1.    The EPCRA section 313 chemical that was
             disposed, stabilized, or treated for destruction
             was received from off-site for the purposes of
             further waste management; or
        2.    The EPCRA section 313 chemical that was
             disposed, stabilized, or treated for destruction
             was manufactured as a result of waste
             management activities on materials received
             from off-site for the purposes of further waste
             management activities.
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                                                  Appendix C
For example, solvents in paint applied to a manufactured
product are  often  misclassified as processed,  instead of
otherwise used. Because the solvents are not incorporated into
the final product, the solvent is being otherwise used, not
processed.

Section 4.  Maximum Amount of the Toxic
Chemical On-site at Any Time During the
Calendar Year

    •   Maximum amount on-site left blank Failure to
        provide the appropriate code for maximum amount
        on site.

Section 5.  Quantity of the Toxic Chemical
Entering Each Environmental Medium On-site

    •   Incorrectly reporting stack emissions.  Fugitive
        emissions from general indoor air should not be
        reported as stack missions when released from a
        single building vent. Additionally, stack emissions
        from storage tanks, including loading, working, and
        breathing  losses  from  tanks,  should  not  be
        overlooked or reported as fugitive emissions.
    •   Overlooking   releases  to  land.  Section   313
        chemicals  placed in  stockpiles  or  in  surface
        impoundments  should be reported as a  "release to
        land"  even if no section  313 chemicals leak  from
        these sources.  Quantities of section 313 chemicals
        land-treated should be reported as a release to land.

Section 6.  Transfers of the  Toxic Chemical  in
Wastes to  Off-site Locations

    •   Reporting discharges to POTWs in Section 6.1.
        When quantities of  a  listed  mineral acid are
        neutralized to a pH  of 6 or greater, the  quantity
        reported as  discharged  to  a  POTW  should  be
        reported as zero. It is incorrect to enter "NA" (Not
        Applicable), in such a situation.
    •   Reporting other off-site transfers in Section 6.2.
        Any quantities reported in Sections 8.1, 8.3, 8.5, and
        8.7  as sent off-site for disposal, treatment, energy
        recovery, or  recycling, respectively, must also be
        reported in Section 6.2 along with the receiving
        location and appropriate off-site activity code.

Section 7A.  On-Site Waste Treatment
Methods and Efficiency

    •   Failure to report waste treatment methods in
        Section 7A. Waste treatment methods used to treat
        waste streams  containing EPCRA  section  313
        chemicals, and the efficiencies of these methods,
        must be reported on Form R. Information must be
        entered for all waste streams, even if the  waste
                                         treatment method does not affect the EPCRA section
                                         313 chemical. If no waste treatment is performed on
                                         waste streams containing the EPCRA section 313
                                         chemical, the box marked Not Applicable in Section
                                         7A should be checked on Form R.

                                     •   Incorrect reporting of waste treatment methods in
                                         Section  7A. The type of waste  stream,  waste
                                         treatment efficiency, and waste treatment method for
                                         each waste stream are required to be reported on
                                         Form R using specific codes. The waste treatment
                                         codes are listed in Appendix B: Reporting Codes for
                                         EPA Form R. A table is also provided in Appendix
                                         B that displays a crosswalk between the old codes
                                         and new ones for reporting year 2005.

                                 Section 7B. On-Site Energy Recovery
                                 Processes

                                     •   Reporting on-site energy  recovery methods  in
                                         Section 7B. When a quantity is reported in Section
                                         8.2 as combusted for energy recovery on-site, the
                                         type of energy recovery system used must be reported
                                         in Section 7B, and vice versa.

                                 Section 7C. On-Site Recycling  Processes

                                     •   Reporting on-site recycling methods in Section
                                         7C. When a  quantity  is reported in Section 8.4 as
                                         recycled on-site, the type of recovery method must be
                                         reported in Section 7C, and vice versa.

                                 Section 8.  Source Reduction and Recycling
                                 Activities

                                 The TRI-MEweb software offers a Section 8 Calculator. The
                                 Section  8 Calculator  will assist users in calculating their
                                 Section 8 source reduction and recycling activity quantities.
                                 Please note that if you use range codes  to report data in
                                 sections 5 and 6, TRI-MEweb will default to the mid-point of
                                 the range when performing section 8 calculations.

                                 The entries in this section must be completed, even if your
                                 facility does not  engage in source reduction  or recycling
                                 activities.

                                     •   Columns C and D, the future year projections for
                                         questions 8.1 through 8.7, must be completed. EPA
                                         expects a reasonable  estimate  for the future year
                                         projections. Zero can be used in columns C and D to
                                         indicate that the manufacture, process, or otherwise
                                         use of the chemical will be discontinued.  In such
                                         cases, columns C and D for Section 8.1 through 8.7
                                         must all contain zeroes.

                                     •   It is incorrect to use range codes to report quantities
                                         in  Section 8. Range  codes can be  used only  in
                                         Sections 5 and 6 of Form R.
                                     •   It is incorrect to use the same codes from Section 4
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                                                Appendix C
    for reporting the maximum amount of the reported
    EPCRA  section 313 chemical  on-site to report
    quantities in Section 8.

•   Quantities reported in Section 8.1 through 8.7 are
    mutually exclusive and  additive. This means that
    quantities of the  reported  EPCRA  section 313
    chemical must not be double-counted in Section 8.1
    through 8.7.
•   Some double-counting  errors have  been due  to
    confusion over  the  differences  in how on-site
    treatment of an  EPCRA section 313 chemical is
    reported in Section 7 A as compared to Section 8. In
    Section 7A, information on the treatment of waste
    streams containing the EPCRA section 313 chemical
    is reported, along with the percent efficiency in terms
    of destruction or removal of the EPCRA section 313
    chemical from each waste stream. In Section 8, only
    the quantity of the EPCRA section 313  chemical
    actually destroyed  through the treatment processes
    reported in Section 7A is reported in Section 8.6 to
    avoid double-counting within Sections 8.1 through
    8.7.
•   Quantities reported in Section 8.1 through 8.7 must
    not be reported in Section 8.8 and vice versa.
•   Any time a reported EPCRA section 313 chemical is
    contained in a waste, and the waste is associated with
    routine production-related activities and is recycled,
    combusted for energy recovery, treated, disposed, or
    otherwise released either on- or off-site, that quantity
    of the EPCRA section 313 chemical must be included
    in the quantities reported in Sections 8.1 through 8.7
•   Reporting quantities in Section 8.1  Quantities of
    EPCRA  section 313 chemicals  that  are released
    (including disposed) on-site and reported in Section 5
    of Form R must be reported in either Section 8. la or
    8.1b.
    §8.1a= § 5.4.1 + § 5.5.1A+ § 5.5.IB - § 8.8 (on-site
    release or disposal due to catastrophic events)1
    § 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 + §
    5.5.3A + § 5.5.3B + §5.5.4 - § 8.8 (on-site release or
    disposal due to catastrophic events)1
    Quantities  of  EPCRA  section   313  chemicals
    transferred  off-site for  the purposes of disposal
    reported in  Section 6.2  using the following codes
    must appear in Section 8. Ic:
     -   M64 Other Landfills
     -   M65 RCRA Subtitle C Landfills
          M81 Underground Injection to Class I Wells
    § 8.1c = § 6.1 (portion of transfer that is untreated
    and ultimately disposed of in UIC Class I Wells,
    RCRA Subtitle C landfills,  and other landfills) + §
    6.2 (quantities associated with M codes M64, M65
        and  M81)   - §  8.8 (off-site disposal  due  to
        catastrophic events)1
        Metals and metal category compounds transferred
        off-site to POTWs in Section 6.1  must appear in
        Section 8. Ic or 8. Id. To report correctly in Sections
        8. la through d, a facility must include quantities that
        are disposed or otherwise released to the environment
        either on-site or off-site, excluding disposal or other
        releases due to catastrophic events or non-production
        related activities.
        Quantities  of  EPCRA  section   313  chemicals
        transferred off-site  for the purposes of disposal
        reported  in Section 6.2 using the following codes
        must appear in Section 8. Id:
          -   M10 Storage Only
              M41 Solidification/Stabilization - Metals and
              Metal Category Compounds Only
              M62 Wastewater Treatment (excluding
              POTW) - Metals and Metal Category
              Compounds Only
              M66 Subtitle C Surface Impoundment
              M67 Other Surface Impoundments
          -   M73 Land Treatment
          -   M79 Other Land Disposal
              M82 Underground Injection to Class II-V
              Wells
          -   M90 Other Off-Site Management
          -   M94 Transfer to Waste BrokerCDisposal
          -   M99 Unknown.
        §8.1d =  §6.1 (portion of transfer that is untreated
        and ultimately disposed of in UIC Class II-V wells,
        and  disposal  other  than  to  landfills) +  §  6.2
        (quantities associated withM codes M10, M41, M62,
        M66, M67, M73, M79, M82, M90, M94, M99)  - §
        8.8 (off-site disposal due to catastrophic events)1

    •   Reporting quantities in Section 8.2  "Quantity
        used for energy recovery on-site." A quantity must
        be reported in Section 8.2 for the current (reporting)
        year when a method of on-site energy recovery is
        reported  in Section 7B,  and vice versa. An error
        facilities make when completing Form R is to report
        the methods of energy  recovery used  on-site in
        Section 7B but not report the total quantity associated
        with those methods. Another error is to report a
        quantity  in this section if the  combustion of the
        EPCRA section 313 chemical took place in a system
        that did not recover energy (e.g., an incinerator). A
        quantity  of the  EPCRA  section  313 chemical
1 §8.8 includes quantities of toxic chemicals disposed or otherwise released
on site or managed as a waste off site due to remedial actions, catastrophic
events, or one-time events not associated with the production processes.
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        combusted for energy recovery must not be reported
        if the EPCRA section 313 chemical does not have a
        significant heating value.  Examples of EPCRA
        section 313 chemicals that do not have significant
        heating values include metals, metal portions of metal
        category compounds, and halons. Metals and metal
        portions of metal compounds will never be treated or
        combusted for energy recovery. Any quantities of the
        EPCRA  section  313  chemical  associated  with
        non-production related activities such as catastrophic
        releases and  remedial actions,  as well  as other
        one-time  events   not  associated  with  routine
        production practices that were combusted for energy
        recovery on-site must not be included in Section 8.8.
    •   Reporting quantities in Section 8.3 "Quantity used
        for energy recovery off-site." As in Section 8.2, a
        quantity must not be reported in this section if the
        off-site  combustion of  the  EPCRA section  313
        chemical took place in a system that did not recover
        energy (e.g., incinerator). A quantity of an EPCRA
        section 313 chemical must not be reported as  sent
        off-site for the purposes of energy recovery if the
        EPCRA section 313  chemical  does  not have a
        significant heating value.  Examples of EPCRA
        section 313 chemicals that do not have significant
        heating values include metals, metal portions of metal
        category compounds, and halons. Metals and metal
        portions of metal category compounds will never be
        combusted for energy recovery.  Quantities must be
        reported in Section 8.3 that are reported in Section
        6.2  as  transferred  off-site  for the  purposes  of
        combustion for energy recovery using the following
        codes:
             M56 Energy Recovery
          -  M92 Transfer to Waste Broker C Energy
             Recovery
        § 8.3 = § 6.2 (energy recovery) - §  8.8 (off-site
        energy recovery due to catastrophic events)2

    •   Reporting quantities in Section  8.4  "Quantity
        recycled on-site." A quantity must be reported in
        Section 8.4 for the current reporting year when a
        method of on-site recycling is reported in Section 7C,
        and  vice  versa. An  error facilities make when
        completing Form R  is to report the  methods  of
        recycling used on-site in Section 7C but not report
        the total quantity recovered using those methods.
        In addition, only the amount of the chemical that was
        actually recovered is to be reported in Section 8.4.
        Any quantities of the EPCRA section 313 chemical
        associated with non-production related activities such
        as catastrophic releases and remedial actions, as well
 §8.8 includes quantities of toxic chemical disposed or otherwise released
on-site or managed as waste off-site due to remedial actions, catastrophic
events, or one-time events not associated with the production processes.
                                          as other one-time events not associated with routine
                                          production practices that were recycled on-site must
                                          not be included in Section 8.8.

                                      •   Reporting quantities in Section 8.5.  "Quantity
                                          recycled off-site." Quantities reported in Section 6.2
                                          as transferred off-site for the purposes of recycling
                                          must be included in Section 8.5 using the following
                                          codes:
                                               M20 Solvents/Organic Recovery
                                            -  M24 Metals Recovery
                                            -  M26 Other Reuse or Recovery
                                            -  M28 Acid Regeneration
                                            -  M93 Transfer to Waste Broker C Recycling.
                                          §8.5 = §6.2 (recycling) - §8.8 (off-site recycling due
                                          to catastrophic events)2

                                      •   Reporting quantities in Section  8.6  "Quantity
                                          treated on-site."  Quantities may not always have to
                                          be reported in Section 8.6 when Section 7A  is
                                          completed. This is because the information reported
                                          in Section 7 A and Section 8 is different. Information
                                          on  how  waste streams  containing  the  reported
                                          EPCRA section 313 chemical are treated is reported
                                          in Section  7A, while  the quantity  of the EPCRA
                                          section 313 chemical actually destroyed as a result of
                                          on-site treatment  is reported in Section 8.6.  If a
                                          quantity is reported in Section 8.6, Section 7A must
                                          be completed but  the reverse may not be true. This
                                          may result in apparent discrepancies between Section
                                          7A and Section 8. For example, a facility may treat
                                          wastewater  containing an  EPCRA  section  313
                                          chemical by  removing the  EPCRA section  313
                                          chemical and  then disposing of it  on-site.  The
                                          treatment of the wastewater would be reported in
                                          Section 7 A, with an efficiency estimate based on the
                                          amount of the EPCRA section 313 chemical removed
                                          from the wastewater. Although the waste stream has
                                          been treated  because  the  EPCRA  section  313
                                          chemical has been removed, the EPCRA section 313
                                          chemical has not been treated because it has not been
                                          destroyed. The facility would report only the amount
                                          of the  EPCRA  section 313 chemical  actually
                                          destroyed  during  treatment  in Section 8.6 and the
                                          amount ultimately disposed  in Section 8.1 to avoid
                                          double-counting the same quantity in Section 8. In
                                          cases where the EPCRA section 313 chemical is not
                                          destroyed   during  a   treatment   process   and
                                          subsequently enters another activity, such as disposal
                                          (e.g.,   metals   removed  from  wastewater  and
                                          subsequently disposed on-site), the quantity of the
                                          EPCRA section 313 chemical would be reported as
                                          disposed in Section 8.1, not as treated in Section 8.6.
                                          Any quantities of the EPCRA section 313 chemical
                                          associated with non-production related activities such
                                          as catastrophic releases and remedial actions, as well
                                          as other one-time events not associated with routine
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        production practices that were treated for destruction
        on-site must not be included in Section 8.8.  Metals
        generally will not be treated for destruction.

    •   Reporting quantities  in  Section  8.7 "Quantity
        treated off-site." Quantities reported in Section 6.2
        as transferred off-site for the purposes of treatment
        must be included in Section 8.7 using the following
        codes:
         -   M40 Solidification/Stabilization
         -   M50 Incineration/Thermal Treatment
         -   M54 Incineration/Insignificant Fuel Value
             M61 Wastewater Treatment (excluding
             POTW)
         -   M69 Other Waste Treatment
         -   M95 Transfer to Waste Broker C Waste
             treatment.
        Quantities  of an EPCRA section 313 chemical,
        except metals and metal category compounds,  sent
        off-site to a POTW should also be reported in Section
        8.7. If you know, however, that a chemical is not
        treated for destruction at  the POTW  you should
        report that quantity in Section 8.1 instead of 8.7.
        To report correctly EPCRA section 313 chemicals in
        Section 8.7, use the following equation.
        §8.7 =§6.1  (excluding most metal/metal category
        compounds)  +  §6.2 (treatment)  - §8.8  (off-site
        treatment due to catastrophic events)3

    •   Reporting quantities  in  Section 8.8 Quantity
        released   to the environment  as  a result of
        remedial actions, catastrophic events or one-time
        events not associated with production processes.
        The quantities that are  reported in Section  8.8 are
        associated with non-production related activities such
        as catastrophic releases and remedial actions, as well
        as  one-time  events  not associated with  routine
        production practices, that were disposed or released
        directly to the environment or transferred off-site for
        the purposes of recycling, energy recovery, treatment
        or disposal. Quantities reported in Section 8.8 must
        not be reported in Section 8.1 through 8.7.

    •   Reporting the production ratio in Section 8.9. A
        production ratio or activity index must be provided in
        Section 8.9. A zero is not acceptable and NA (Not
        Applicable) can be used only when  the reported
        EPCRA section 313 chemical was not manufactured,
        processed, or otherwise used in the year prior to the
        reporting year.

    •   Calculating  production ratio in  Section 8.9.  In
3§8.8 includes quantities of toxic chemical disposed or otherwise released
on-site or managed as waste off-site due to remedial actions, catastrophic
events, or one-time events not associated with the production processes.
        calculating a production ratio for otherwise used
        chemicals, an activity index must be used rather than
        quantities purchased or released from year to year.

    •   Reporting source reduction activities in Section
        8.10.  It  is an error to  report a source reduction
        activity in Section 8.10 and not report at least one
        method used to identify that activity and vice versa.


C.4  FDP  Messages Used to

Report  Notices of

Significant  Errors

Note:   EPA is continually  trying to improve the  error
        checking system for TRI submissions.  As a result, a
        small number of the error messages in this appendix
        may be changed by the time the Reporting Year 2009
        submissions are checked.  Most of these messages
        will remain the same.  You can look for changes to
        these error messages on  the TRI  home  page at
        http://www.epa.gov/tri
1.       You have used an invalid Form R or Form A by using
        either a form not applicable for the reporting year, or
        a facsimile form that has not been approved by EPA.
        Resubmit your data on a current EPA approved Form
        RorA.
2.       Pages were missing from the form received. Correct
        this by resubmitting a complete certified form for this
        chemical substance.
3.       Multiple chemicals were reported in your Form R.
        You must submit a separate and complete Form R for
        each chemical cited.
4.       You have provided a valid CAS number and a valid
        chemical name, but they do not match. Respond by
        providing  a valid CAS  number  and  matching
        chemical name.
5.       You have left part or all of the chemical identification
        sections blank.  Respond by providing a valid CAS
        number and matching chemical name or Mixture
        Component Identity.
6.       You reported a CAS number and chemical name that
        are  invalid. Respond by providing  a valid  CAS
        number and matching chemical name.
7.       Your form indicated  Trade  Secret status with an
        indication that this form is a Sanitized version, but
        the report contains no Generic Chemical Name. You
        must provide a Generic Chemical Name for this
        sanitized form.
8.       You did not sign the Form   Per EPCRA Section
        313(g)(l)(B),  each submission must contain an
        original signature  certifying  the  accuracy  and
        completeness of the information reported by signing
        the certification statement on the Form or certified
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                                               Appendix C
       letter. Please be  sure to sign the certification
       statement in this FDP to certify your submission data.
9.      You  have  reported  Dioxin  and Dioxin-like
       Compounds on a Form A.  Dioxin and Dioxin-like
       Compounds  are  not eligible  for  the  alternate
       threshold.  Thus, this chemical must be reported on a
       Form R. Please resubmit your data on a Form R.
10.     In Part  I, Section  lof the Form R or Form  A
       Certification Statement You did not enter a reporting
       year. (Note:  EPA  has set the year  to 2084 as a
       default.)  You must enter a valid reporting year for
       your Form R or Form A Certification Statement.
       This entry cannot be left blank and NA may not be
       used. (NOSE)
11.     In Part  I, Section  lof the Form R or Form  A
       Certification Statement you provided an invalid or
       future reporting year.  You  must enter a valid
       reporting year  for your Form R or  Form  A
       Certification Statement. Valid years are 1987 through
       2002. This entry cannot be left blank and NA may
       not be used. (NOSE)
12.     You have reported a negative number(s) in Part II,
       Sections  5 and/or 6 and/or  8 of your Form R.
       Quantities reported  in these sections must be  0 or
       greater.  Please respond by providing correct release
       or other waste management data.
13.     You did not complete Part II, Sections 5  and  6.
       Please provide the  required information; otherwise
       indicate NA.
14.     You did not complete Part II,  Section 7.  Please
       provide the required information; otherwise indicate
       NA.
15.     You did not complete Part II,  Section 8.  Please
       provide the required information; otherwise indicate
       NA.
C.5  Messages Used to
Report Notices of Technical
Errors (NOTEs) and  Non-
technical Data Changes
(NDCs)

Invalid codes throughout Form R
16.      You submitted an invalid code. To correct this,
        consult the instructions for the proper table value and
        provide a valid code value. [Specific location on the
        form of the invalid code is given.] (NOTE)
17.      PBT  chemicals  (e.g.,  Dioxin  and Dioxin-like
        Compounds, Lead Compounds, Mercury Compounds
        and Polycyclic Aromatic Compounds (PACs)) are
                                       ineligible for range reporting for on-site releases and
                                       transfers off-site for  further waste management.
                                       Please provide specific release, transfer, and other
                                       waste management values. (NOTE)
                               18.     For aluminum (fume or dust) or zinc (fume or dust),
                                       the Waste Management codes M56 and M92 are
                                       unacceptable.  Please  provide the proper Waste
                                       Management codes for these chemicals. (NOTE)
                               19.     For asbestos (friable), the Waste Management codes
                                       M56 and M92 are unacceptable. Please provide the
                                       proper Waste Management codes for these chemicals.
                                       (NOTE)

                               General Errors for both the Form R and/or
                               Form A

                               20.     You reported a negative value for a release, transfer
                                       or other waste management quantity. Please provide
                                       a  non-negative  value for  the specified part and
                                       section. (NOTE)
                               21.     You have reported a value for a PBT chemical
                                       beyond seven digits to the right of the decimal.
                                       EPA's  data  management  systems support  data
                                       precision up  to seven digits  to the right of the
                                       decimal.   EPA  has  truncated  your numeric
                                       submission so the number of digits to the right of the
                                       decimal do not exceed seven.  If this was incorrect,
                                       specify the correct value, not exceeding seven digits
                                       to the right of the decimal. (NDC)

                               Errors in Part I, Facility Identification
                               Information

                               22.     No selection was made in Part I, Section 2.1 and 2.2
                                       (Trade Secret Information) and a generic chemical
                                       name was not provided in Part II,  Section 1.3.
                                       Therefore, the No box was selected in Part I, Section
                                       2.1. If this was incorrect, and you intended to make a
                                       trade  secret claim of the identity of the toxic
                                       chemical,  you must  resubmit  following   the
                                       requirements  of 40 CFR Part 350 to claim trade
                                       secret. (NDC)
                               23.     You indicated trade secret in Part I,  Section 2.1
                                       (Trade Secret Information) but made no selection for
                                       Part I, Section 2.2 (sanitized/unsanitized) and did not
                                       provide a generic chemical name in Part II, Section
                                       1.3.  EPA changed your selection in Part I, Section
                                       2.1 to indicate that a trade secret claim is not being
                                       made.   If this was incorrect, and you intended to
                                       make a trade secret claim for the identity of the toxic
                                       chemical,  you must  resubmit  following   the
                                       requirements  of 40 CFR Part 350 to claim trade
                                       secret. (NDC)
                               24.     You made a selection of No in Part 1, Section 2.1
                                       (Trade Secret Information) and selected unsanitized
                                       in Part 1, Section 2.2.  In Part II, Section 1.3 a
                              	generic name was indicated.   Part II, Section 1.3
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                                                   Appendix C
        should be completed only if trade secret is being
        claimed (Part 1, Section 2.1).  EPA will move the
        chemical name information in Part II, Section 1.3 to
        Part II, Section 1.2. If this is incorrect and you wish
        to claim trade secret, you must resubmit following the
        requirements of 40 CFR Part 350. (NDC)
25.     In Part I, Section 4.1, you entered NA or did not
        enter a county name, city name, state code, and/or zip
        code.  These fields may not be left blank and NA is
        not an acceptable entry.  You must provide a county
        name, city name, state code, and/or zip code where
        the facility is located. (NDC)
26.     EPA has corrected the county name, city name, state
        code, and/ or zip code that you identified in Part I,
        Section 4.1.  The county name, city name, state code,
        and/ or zip code that you identified was either mis-
        spelled, or incorrect, or did not match the previous
        year  submissions.   If you feel our correction was
        made  in  error, please resubmit forms  with  correct
        information.  (NDC)
27.     In Part I, Section  4.1,  you have used an  invalid
        TRIFID or you have self-assigned your own TRIFID
        or TRIFID that has been superceded. You may not
        generate your own TRIFID. The TRI Data Processing
        Center assigns this number to a facility. EPA has
        corrected this  error and assigned you the  correct
        TRIFID.  Please note the corrected TRIFID and keep
        it for use in future submissions. (NDC)
28.     No Public Contact name and/or  telephone number
        was listed. Please provide the name and telephone
        number of your Public Contact. (NOTE)
29.     No Technical Contact name and/or telephone number
        was listed. Please provide the name and telephone
        number of your Technical Contact.  (NOTE)
30.     The Federal  Facility box was not checked on your
        form but we believe you are a Federal Facility.
        Unless you  respond that you are  not a  Federal
        Facility, we will continue to treat you  as a Federal
        Facility.  (NOTE)
31.     A  valid NAICS code  was not provided.  Please
        provide at least one valid primary six-digit NAICS
        code.  (NOTE)
32.     You reported an invalid state code.  If the address is
        in the US, please use a valid US Postal Service state
        code (see  Table III of the Reporting Forms and
        Instructions). If the address is not in the US, please
        enter a valid code in the Country Field (see Table IV
        of the Reporting Forms and Instructions) (NOTE)
3 3.     Either Box A (An Entire Facility) or Box B (Part of a
        Facility) should be checked in Part I, Section 4.2.
        One of the 2 boxes must be checked, but not both.
        (NOTE)
        If applicable, check either Box C (Federal Facility) or
        Box D (GOCO) in Part I, Section 4.2, but do not
        check both boxes. (NOTE)
        You did not enter Longitude or Latitude values for
        the  facility. Please enter a Longitude and Latitude
        value. (NOTE)
36.      You entered an invalid Longitude/Latitude value(s).
        Longitude degrees must be  between 0 and  180,
        latitude degrees must be between 0 and 90; minutes
        and seconds for either latitude or longitude must be
        between 0 and 60. (NOTE)
37.      Dun and Bradstreet Numbers (Part I Section 4.7) are
        typically  9  characters in length. Please check the
        number(s) submitted. If they are incorrect, please
        make the appropriate changes.  If you believe that
        they are  correct,  no further action is  necessary.
        (NOTE)
38.      EPA Identification Numbers (RCRA I.D. No. Part I
        Section 4.8) are typically 12 characters in length.
        Please check  the number(s) submitted. If they are
        incorrect, please make the appropriate changes.  If
        you believe that they are correct, no further action is
        necessary. (NOTE)
39.      NPDES  Permit Numbers  (Part I, Section  4.9) are
        typically  9  characters in length. Please check the
        number(s) submitted. If they are incorrect, please
        make the appropriate changes.  If you believe that
        they are  correct,  no further action is  necessary.
        (NOTE)
40.      Underground  Injection  Well  Code  (UIC)  I.D.
        Numbers (Part I, Section 4. 10) are typically 12 digits.
        Please check the number(s) you have supplied. If they
        are  incorrect,  please make appropriate changes. If
        you believe that they are correct, no further action is
        necessary. (NOTE)
41.      If this is  a North  American phone number, please
        enter all 10  digits (i.e., include area code).  If this is
        for another country, please begin the phone number
        with "Oil"  as the prefix  to  your  international
        telephone number. (NOTE)
42.      In Part I, Section 3, you did not provide a printed or
        typed name and official title of owner/operator or
        senior management official. It cannot be N/A or left
        blank. Please provide a name for owner/operator or
        senior management official. (NOTE)
43.      In Part I, Section 5.1 you did not enter the  name of
        the parent company. This block cannot be left blank.
        You must enter the name for the parent company if it
        is a U. S. company. If it is a foreign company then you
        may check the [NA] box. (NOTE)
44.      The parent company Dun and Bradstreet Number in
        Part I,  Section 5.2  (typically a 9-digit number  )
        cannot  be  left blank.  However,  if  your parent
                            Toxics Release Inventory Reporting Forms and Instructions
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                                                 Appendix C
        company  does not have  a  Dun  and Bradstreet
        Number check the [NA] box next to Part I, Section
        5.2. (NOTE)

Errors in Part II, Section 1. Toxic Chemical
Identity

45.      You have correctly identified the chemical but have
        used a  synonym for the chemical name. EPA has
        changed the Chemical Name to use the preferred TPJ
        nomenclature. Please specify  the  correct  CAS
        Number and matching Chemical Name. (NDC)
46.  The CAS number you reported was changed to match the
        chemical name reported, because the CAS number
        you provided was not a valid TRI Chemical. If this
        was incorrect, specify a valid CAS number and
        matching chemical name. (NDC)
47.      The chemical name you reported was changed to
        match  the  CAS number reported, because the
        chemical name you provided was not a valid TRI
        Chemical. If this was incorrect, specify a valid CAS
        Number and matching Chemical Name. (NDC)
48.      You reported a  valid TRI CAS Number, a valid
        Chemical Name, and a generic Chemical Name.
        Therefore, the Generic Chemical Name was deleted.
        If this was incorrect, specify the Generic Chemical
        Name to be used. (NDC)
49.      You reported a  valid TRI CAS Number, a valid
        Chemical Name,  and a Mixture Component Identity.
        Therefore,  the Mixture  Component Identity was
        deleted. If this was incorrect, specify the Mixture
        Component Identity to be used.  (NDC)
50.      EPA has changed the TRI chemical category code
        you reported in Part II,  Section 1.1 from N151 to
        N150 (the code was incorrectly listed in some pages
        of the Reporting Forms and Instructions), the correct
        TRI chemical category code for Dioxin and Dioxin-
        like Compounds. If this is incorrect and you are not
        reporting Dioxin and Dioxin-like Compounds, please
        specify  the correct CAS number or chemical category
        code and matching chemical name.(NDC)
51.      You have  reported for isopropyl  alcohol (Only
        persons who manufacture by the strong acid process
        are subject) (CAS number 67-63-0). If you did not
        manufacture  isopropyl alcohol  by  the strong acid
        process, you have submitted this form in error and
        should request that the form be withdrawn. (NOTE)

Errors in Form R, Part II,  Section 1.4. Dioxin
and Dioxin-like Compounds

52.      EPA has deleted the entry of zeros in Part II, Section
        1.4 because you indicated a CAS number or chemical
        category in Part II, Section 1.1 other than Dioxin and
        Dioxin-like Compounds.  When reporting  for a
        chemical   other  than   Dioxin  and  Dioxin-like
                                        Compounds, you should leave Section 1.4 blank.
                                        (NDC)


                                 53.     You did not complete Section 1.4. If you report
                                        Dioxin  and Dioxin-like Compounds  in  Part  II,
                                        Sections 1.1 or 1.2, you must complete Section 1.4.
                                        Please report the distribution of chemicals included
                                        for Dioxin and Dioxin-like Compounds. If you  do
                                        not have speciation data available, indicate NA.
                                        (NOTE)
                                 54.     Part II, Section 1.4 of your Form R contains data for
                                        Dioxin and Dioxin-like Compounds.  However, you
                                        have indicated a CAS number or chemical category
                                        code in Part II, Section 1.1 other than Dioxin and
                                        Dioxin-like Compounds (N150). If you are reporting
                                        for Dioxin and Dioxin-like  Compounds, please
                                        provide the proper chemical category code (N150).
                                        Otherwise please indicate on the FDP that Section 1.4
                                        should be left blank. (NOTE)
                                 55.     You did not provide values in all 17 boxes in Part II,
                                        Section 1.4 and/or the values do not total to 100%.
                                        When reporting the distribution of each member of
                                        the Dioxin and Dioxin-like Compounds category, you
                                        must fill in each of the 17 boxes in Part II, Section
                                        1.4 witheitherO or a number between 0.01 and 100.
                                        The summation of the 17 fields in Section 1.4 must
                                        equal 100. Please review Part II, Section 1.4 and
                                        enter  values  where  needed  and/or adjust  the
                                        percentages where needed so  that their summation
                                        equals 100%. (NOTE)
                                 56.     You reported numeric values in Part II, Section 1.4
                                        for a  chemical that is not Dioxin and Dioxin-like
                                        Compounds. It appears that the information reported
                                        in Part  II,  Section 1.4 is not valid.  If  you are
                                        reporting for Dioxin and Dioxin-like Compounds,
                                        please indicate on this FDP that the  chemical
                                        category name  in Part II, Section 1.2 should  be
                                        Dioxin and Dioxin-like Compounds, or submit a new
                                        Form R. Otherwise, please indicate on this FDP that
                                        the values in Part II, Section 1.4 should be blank.
                                        (NOTE)
                                 57.     Part II, Section 1.4 of your Form R contains data for
                                        Dioxin and Dioxin-like Compounds.  However, you
                                        have indicated both NA and a numeric value (which
                                        includes zero).  When reporting the distribution of
                                        each  member  of  the Dioxin  and  Dioxin-like
                                        Compounds category, you must fill in each of the  17
                                        boxes in Part II, Section 1.4 with either 0 or a number
                                        between 0.01 and 100.  The summation of the  17
                                        fields in Section 1.4 must equal 100. If you do not
                                        have speciation data available, indicate NA rather
                                        than zero. (NOTE)
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Toxics Release Inventory Reporting Forms and Instructions

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                                                 Appendix C
Errors in Part II, Section 3. Activities and Uses
of Toxic Chemical At The Facility

58.      You did not indicate in Part II, Section 3 which
        activity(ies) or use(s) of the EPCRA section 313
        chemical occur at your  facility. Please indicate at
        least one of the activity(ies) and use(s) of the EPCRA
        section 313 chemical occur at your facility. (NOTE)

Errors in Part II, Section 4. Maximum Amount
of the Toxic Chemical Onsite At Any Time
During the Calendar Year

59.      You did not complete Part II, Section 4.1. Please
        provide a valid two digit code for the "maximum
        amount of chemical on-site at any time during the
        calendar year." (NOTE)

Errors in Part II, Section 5. Quantity of the
Toxic Chemical Entering Each Environmental
Medium Onsite

60.      You did not complete Part II, Section 5.3. If you have
        discharged to water, please provide the Stream/Water
        Body name,  the Release  estimate  or range code,
        Basis of Estimate and %from Stormwater; otherwise
        indicate "NA" (Not Applicable). (NOTE)
61.      There  are missing or incomplete data for Part II,
        Section 5.3. If you have discharged to water, please
        provide the Stream/Water Body name, the Release
        estimate or range code, Basis of Estimate and %from
        Stormwater;  otherwise   indicate   "NA"  (Not
        Applicable).  (NOTE)
62.      You did not complete  Part II, Section 5. Please
        provide the Release estimate or range code and Basis
        of Estimate; otherwise   indicate  "NA"  (Not
        Applicable).  (NOTE)
63.      There  are missing or incomplete data for Part II,
        Section 5.  Please provide the Release estimate or
        range code and Basis of Estimate; otherwise indicate
        "NA" (Not Applicable). (NOTE)

Errors in Part II, Section 6. Transfers of the
Toxic Chemical In Wastes To Off-Site
Locations

64.      You  did  not  complete   Part  II,  Section  6.1,
        "discharges to POTW." If you did not discharge
        wastewater containing the section 313 chemical to a
        POTW(s),  enter "NA" (Not Applicable), otherwise
        please provide the  Transfer amount or range code,
        Basis  of Estimate, POTW Name  and  Location.
        (NOTE)
65.      You reported a POTW(s) name and location but did
        not provide a Transfer amount. Please  provide a
        Total Transfer amount or range code and Basis of
        Estimate;  otherwise, if there was no transfer to a
        POTW of wastewater that contains or contained the
        section 313 chemical, delete the POTW location and
        indicate "NA"  (Not Applicable) for the  POTW
        transfer amount.  (NOTE)
66.      You reported a Total Transfer amount or range code
        and Basis of Estimate in Part II Section 6.1 but did
        not indicate a POTW name and location in Section
        6.1 .B. Please provide the POTW Name and Location.
         (NOTE)
67.      You provided an incomplete  POTW  name and
        address.  Please  provide the name  and complete
        address for the POTW. (NOTE)
68.      There  are missing or incomplete data for  Part II,
        Section 6.1. Please provide the transfer amount or
        range code and Basis of Estimate for Discharges to
        POTWs. (NOTE)
69.      You did not complete Part II, Section 6.2, "Transfers
        to Other Off- site Locations." If you did not transfer
        the waste containing the section 313 chemical to
        other off-site locations, enter "NA" (Not Applicable),
        otherwise  please provide Offsite EPA  ID, Name,
        Location,  Transfer amount or range  code, Basis of
        Estimate,  and type of Waste Management code.
        (NOTE)
70.      You reported an Off-site Transfer amount or range
        code and Basis of Estimate in Part II Section 6.2 but
        did not indicate  an Off-site name and  location in
        Section 6.2. Please provide the Off-site Name and
        Location.   (NOTE)
71.      You reported an Off-site name and location but did
        not provide a Transfer amount. Please provide a
        Total  Transfer amount or  range code, Basis  of
        Estimate and  type  of Waste Management code;
        otherwise, if there was no transfer to this  Off-site
        location,  delete the Off-site name and location and
        indicate "NA" (Not Applicable) in the Off-site EPA
        Identification  Number  (RCRA  ID  No.) field.
        (NOTE)
72.      You provided both county and country data.  If this is
        an extra-national transfer, indicate the off-site name,
        address, and Country Code; if a domestic  Offsite,
        provide the Off-site Name  and correct  address.
        (NOTE)
73.      You reported an Off-site name and location, but there
        are missing or incomplete data for the off-site transfer
        amount,  basis  of estimate  and type of waste
        management code. Please  provide the   Off-site
        Transfer amount or range code, Basis of Estimate,
        and type of Waste Management code. (NOTE)
74.      You provided incomplete off-site name and address
        data. For a transfer to  a domestic off-site location,
        you must provide a street address, city, state, county
        and zip code. For a transfer to a foreign off-site
                           Toxics Release Inventory Reporting Forms and Instructions
                                               C-13

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                                                   Appendix C
        location, you must provide a street address, city and a
        two character country code. (NOTE)
75.      You reported an invalid Type of Waste Management
        code. For metals/metal compounds use only disposal
        and certain recycling activities codes. Consult the
        Reporting   Instructions  for  metal  and  metal
        compounds  and  correct  with  a valid  Waste
        Management (i.e., "M") code.  (NOTE)
76.      You reported an invalid Type of Waste Management
        code. For Barium Compounds use only disposal and
        certain recycling activities codes, M61-Wastewater
        Treatment (Excluding POTW) or M69-Other Waste
        Treatment.  Consult the Reporting  Instructions for
        metal and metal compounds and correct with a valid
        Waste Management (i.e., "M") code. (NOTE)
77.      For  non-metals   codes  M41   and  M62   are
        unacceptable. Provide the appropriate Disposal or
        Other Waste Management code for this non-metal
        substance.  (NOTE)
78.      In Part II, Section 6.2 column C you reported M
        codes (M56  and/or M92)  for  energy recovery,
        however you left Section 8.3 column B blank. Please
        provide the quantity used for energy recovery offsite
        in pounds/year in Section 8.3 column B. (NOTE)
79.      In Part II, Section 6.2 column C you reported M
        Codes (M20, M24, M26, M28, M93) for recycling,
        however you left Section 8.5 column B blank. Please
        provide the quantity recycled offsite in pounds/year
        in Section 8.5 column B. (NOTE)
80.      In Part II, Section 6.2 column C you reported M
        Codes  (M40, M50, M54,  M61,  M69, M95) for
        treatment, however you left Section 8.7 column B
        blank. Please provide the quantity treated offsite in
        pounds/year in Section 8.7 column B. (NOTE)

Errors in Part II, Section 7. On-Site Waste
Treatment Methods and Efficiency

81.      There are no data contained in all of Part II, Section
        7 A. If you do not treat wastes containing the EPCRA
        section 313 chemical at your facility, indicate "NA;"
        otherwise please provide the  general waste stream
        code,  waste treatment methods, range  of influent
        concentration, waste treatment efficiency estimate
        and whether this is based on operating data for all on-
        site waste treatments for this chemical.  (NOTE)
82.      There are missing data in Part II, Section 7 A. Please
        provide the general waste  stream  code,  waste
        treatment methods, range of influent concentration,
        waste treatment efficiency estimate and whether this
        is based on operating data. (NOTE)
83.      There are no datainPartll, Section 7B.  If no on-site
        energy recovery processes are used for this section
        313  chemical at your  facility,  indicate  "NA;"
                                         otherwise please provide at least one three-character
                                         on-site energy recovery process code. (NOTE)
                                 84.     There are no datainPartll, Section 7C. If no on-site
                                         recycling processes are used for this section 313
                                         chemical at your facility, indicate "NA;" otherwise
                                         please provide at least one  three-character on-site
                                         recycling process code. (NOTE)

                                 Errors in Part II, Section 8. Source Reduction
                                 and Recycling Activities

                                 85.     There are missing data for Part II, Section 8.1-8.7.
                                         Please provide an estimate or"NA" (Not Applicable)
                                         in each box for section 8.1 through 8.7, columns A,
                                         B, C, and D.  You  may  only  use "NA" (Not
                                         Applicable) when there is no possibility a release or
                                         transfer occurred.  You may enter zero if the release
                                         or transfer was equal to or less than half a pound.
                                         (NOTE)
                                 86.     There are missing data in Part II, Section 8.8. Please
                                         provide an estimate or "NA" (Not Applicable). You
                                         may  only use "NA" (Not Applicable) when there is
                                         no possibility a release or transfer occurred. You
                                         may  enter zero if the release or transfer was equal to
                                         or less than half a pound. (NOTE)
                                 87.     There are no data in Part II, Section 8.9. Please
                                         provide a production ratio, an activity index, or "NA"
                                         (Not Applicable) if the chemical manufacture or use
                                         began during the current reporting year. (NOTE)
                                 88.     There are no data in Part II, Section 8.10.  If your
                                         facility did not  engage in  any source reduction
                                         activity for the reported chemical, enter "NA" (Not
                                         Applicable) and  answer 8.11.   Otherwise please
                                         provide Source Reduction Activities and Methods
                                         code(s). (NOTE)
                                 89.     There  are missing data in  Part II,  Section 8.10.
                                         Please provide  Source Reduction  Activities and
                                         Methods code(s).  (NOTE)
                                 90.     Neither box was checked in section 8.11.  Please
                                         check one of the boxes in section 8.11 indicating if
                                         additional information on source reduction, recycling,
                                         or pollution control activities is included with your
                                         Form R report. (NOTE)
                                 91.     You have reported a listed metal or metal compound
                                         category in section 8.2, 8.3, 8.6 or 8.7. However,
                                         these chemicals cannot be treated for destruction.
                                         Metal  or metal compound  category can  only  be
                                         reported  as  disposed or recycled. Please report
                                         appropriately in Section 8.1,  8.4, or 8.5. (NOTE)
                                 92.     You reported a negative value for a release, transfer
                                         or other waste management quantity. Please provide a
                                         non-negative value for the specified part and section.
                                         (NOTE)
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                                                   Appendix C
Errors relating to the reconciliation of data in
Part II, Section 8 and Part II, Sections 5, 6, and
7

93.     You did not complete Sections 8.1  through 8.7
        column B or 8.8. If you report releases in Part II,
        Section 5 and/or an off-site transfer in Section 6.2
        and/or quantities transferred off-site to POTWs in
        Section 6.1, you must report an estimate in Part II,
        Sections 8.1 through 8.7 column B and/or Section
        8.8. (NOTE)
94.     You did not complete Sections 5,6, or 7. If you enter
        an estimate  in Part II, Sections  8.1  through 8.7,
        column B and/or Section 8.8, you must also report
        releases in Part II, Section 5 and/or off-site transfers
        in Section 6.2 and/or quantities transferred off-site to
        POTWs in Section 6.1 and/or waste treatment, energy
        recovery, or recycling codes in Section 7.  Please
        provide data for Sections 5, 6, and/or 7. (NOTE)
95.     You reported an estimate  in Part II,  Section 8.2,
        column B, "Quantity Used for Energy Recovery On-
        site," but did not provide an on-site energy recovery
        code in Part II, Section 7B. Please provide an on-site
        energy recovery code  for Part II,  Section 7B.
        (NOTE)
96.     You reported an "On-site Energy Recovery Process"
        code in Part II, Section 7B, but you did not provide
        an estimate of the quantity used for energy recovery
        in Part II, Section 8.2, column B. Please provide an
        estimate of the quantity used for energy recovery for
        Part II, Section 8.2, column B.  (NOTE)
97.     You reported an estimate  in Part II,  Section 8.4,
        column B "Quantity Recycled On-site" but did not
        provide an on-site recycling code in Part II, Section
        1C.  Please provide an on-site recycling code for Part
        II, Section 7C. (NOTE)
98.     You reported one or more on-site recycling process
        codes in Part II, Section 7C but did not provide an
        estimate in Part II, Section 8.4, column B, "Quantity
        Recycled On-site." Please provide an estimate of the
        quantity recycled for Section 8.4 column B. (NOTE)
99.     You reported a value in Part II, Section 8.3 column
        B, however  you did not provide a corresponding
        quantity  with  an   appropriate  M   Code   (M56
        and/orM92)  for energy recovery in  Section 6.2
        column C. Please provide the appropriate quantity
        and M Codes for energy recovery in Section 6.2
        column C. (NOTE)
100.    You reported a value in Part II, Section 8.5 column
        B, however  you did not provide a corresponding
        quantity with an appropriate M Code  (M20, M24,
        M26, M28, M93) for recycling in Section6.2 column
        C. Please provide the appropriate quantity  and M
        Codes for recycling in Section  6.2  column  C.
        (NOTE)
101.     You reported a value in Part II, Section 8.7 column
        B, however you did not report a quantity in Section
        6.1 or a quantity with an appropriate M Code (M40,
        M50, M54, M61, M69, M95) for treatment in Section
        6.2 column C. Please provide a quantity in Section
        6.1 or the appropriate quantity and M Codes for
        treatment in Section 6.2 column C. (NOTE)
102.     You have reported a listed metal or metal compound
        category in Part II,  Section 6.1, however you have
        not  provided  a quantity  released in  section  8.1
        column B. Note that in Section 8a, metal or metal
        compound category can only be reported as disposed
        or recycled and not reported as treated for energy
        recovery or treated for destruction. Please provide
        quantity released in  pounds/year  in  Section  8.1
        column B. (NOTE)
103.     You have reported a listed metal or metal compound
        category in Part II,  Section 6.1, however you have
        not provided quantity released in 8. Id Column B.
        Note that in Section 8a, metal or metal compound
        category can only be reported as disposed or recycled
        and not reported as treated for energy recovery or
        treated  for destruction.   Please provide quantity
        released in pounds/year Section 8. IB. (NOTE)
                            Toxics Release Inventory Reporting Forms and Instructions
                                                C-15

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Appendix  D.    Supplier Notification  Requirements
EPA requires some suppliers of mixtures or other trade name
products containing one or more of the EPCRA section 313
chemicals to notify their customers. This requirement has been
in effect since January 1, 1989.

This appendix explains which suppliers must notify  their
customers, who must be notified, what form the notice  must
take, and when it must be sent.
D.1  Who  Must Supply

Notification

You  are covered by the section 313  supplier notification
requirements if you own or operate a facility which meets all
of the following criteria:

1.      Your  facility  is  in a  North American Industry
       Classification System (NAICS) code that corresponds
       to Standard Industrial Classification [SIC] codes 20-
       39;
2.      You manufacture (including import) or process an
       EPCRA section 313 chemical; and
3.      You sell or otherwise distribute a mixture or other
       trade name product containing the  EPCRA section
       313 chemical to either:
         -  A facility in a covered NAICS code (see
            Table I).
         -  A person that then may sell the same mixture
            or other trade name product to a firm in a
            covered NAICS code (see Table I).
Note that you may be covered by the supplier notification
rules even if you are not covered by the section 313 release
reporting requirements.  For example, even if you have
fewer than 10 full-time employees or do not manufacture or
process any of the EPCRA section 313 chemicals in sufficient
quantities to trigger the release and other waste management
reporting requirements, you may still be required to notify
certain customers.
D.2  Who  Must Be  Notified

Industries whose primary NAICS code does not correspond to
SIC codes  20 through 39 are not required to initiate the
distribution of notifications for EPCRA section 313 chemicals
in mixtures or other trade name products that they send to their
customers.

However, if these facilities receive notifications from their
suppliers about EPCRA section 313 chemicals in mixtures or
other  trade  name products,  they  should  forward  the
notifications with the EPCRA section 313 chemicals they send
to other covered users.

An example would be if you sold a lacquer containing toluene
to  distributors who then  may sell the product to other
manufacturers. The distributors are not in a covered NAICS
code, but because they sell the product  to companies in
covered NAICS codes, they must be notified so that they may
pass the notice along to their customers, as required.

The language of the supplier notification requirements covers
mixtures or other  trade name products that are sold or
otherwise distributed.  The "otherwise distributes" language
includes intra-company transfers and, therefore, the supplier
notification requirements at 40 CFR Section 372.45 apply.
D.3  Supplier Notification

Content

The  supplier  notification  must  include the following
information:

1.      A statement that the mixture or other trade name
       product contains an EPCRA section 313 chemical or
       chemicals subject to the reporting requirements of
       EPCRA section 313 (40 CFR 372);
2.      The name of each EPCRA section 313 chemical and
       the associated Chemical Abstracts Service (CAS)
       registry number of each chemical if applicable. (CAS
       numbers are not used for chemical categories, since
       they can represent several individual EPCRA section
       313 chemicals.); and
3.      The percentage, by weight, of each EPCRA section
       313 chemical (or all EPCRA section 313 chemicals
       within a listed category) contained in the mixture or
       other trade name product.
For example, if a mixture contains a chemical (i.e., 12 percent
zinc oxide) that  is a member of a reportable EPCRA section
313 chemical category (i.e., zinc compounds), the notification
must indicate that the mixture contains a zinc compound at 12
percent by weight. Supplying only the weight percent of the
parent metal (zinc) does not fulfill  the requirement. The
customer  must  be told the weight percent of the entire
compound within an EPCRA section 313 chemical category
present in the mixture.
                          Toxics Release Inventory Reporting Forms and Instructions
                                              D-l

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                                                Appendix D
D.4  How  the  Notification

Must Be  Made

The required notification must be provided at least annually in
writing.  Acceptable forms of notice include letters, product
labeling, and product literature distributed to customers. If
you are required to prepare and distribute a Material Safety
Data Sheet (MSDS) for the mixture under the Occupational
Safety and  Health Act (OSHA) Hazard Communication
Standard, your section 313 notification must be attached to the
MSDS or the MSDS must be modified to include the required
information.  (A sample letter  and recommended text for
inclusion in an MSDS appear at the end of this appendix.)

You must make it clear to your customers that any copies or
redistribution of the MSD S or other form of notification must
include the section 313 notice. In other words, your customers
should understand their requirement to include the section 313
notification if they give your MSDS to their customers.


D.5  When Notification  Must

Be Provided

You must notify each customer receiving a mixture or other
trade  name product containing an EPCRA section  313
chemical with the first shipment of each calendar year.  You
may send the notice with subsequent shipments as well, but it
is required that you send it with the first shipment each year.
Once customers have been provided with an MSD S containing
the section 313 information, you may refer to the MSDS by a
written letter in subsequent years (as long as the  MSDS is
current).

If EPA adds EPCRA section 313 chemicals to the section 313
list, and your products contain the newly added EPCRA
section 313  chemicals, notify your customers with the first
shipment made during the next calendar year following EP A's
final decision to add the chemical to the list. For example, if
EPA adds chemical  ABC  to the list  in September 1998,
supplier notification for chemical AB C would have begun with
the first shipment in 1999.

You must send a new or revised notice to your customers if
you:

1.       Change a  mixture  or other trade name product by
        adding, removing, or  changing the  percentage by
        weight of an EPCRA section 313 chemical; or
2.       Discover that your previous  notification did not
        properly identify the EPCRA section 313 chemicals
        in the mixture or correctly indicate the percentage by
        weight.
                                In these cases, you must:

                                1.      Supply a new or revised notification within 30 days
                                       of a change in the product or the discovery of
                                       misidentified EPCRA section 313 chemical(s) in the
                                       mixture or incorrect percentages by weight; and
                                2.      Identify in the notification the prior shipments of the
                                       mixture or product in that calendar year to which the
                                       new  notification   applies  (e.g.,  if the  revised
                                       notification is  made on August 12, indicate which
                                       shipments were affected during the period January 1 -
                                       August 12).


                                D.6  When Notifications Are

                                Not Required

                                Supplier notification is not required for a "pure" EPCRA
                                section 313 chemical unless a trade name is used. The identity
                                of the EPCRA section 313 chemical will be known based on
                                label information.

                                You are not required to make a "negative declaration." That
                                is, you are not required to indicate that a product contains no
                                EPCRA section 313 chemicals.

                                If your mixture or other trade name product contains one of the
                                EPCRA section 313 chemicals, you are not required to notify
                                your customers if:

                                1.      Your mixture or other trade name product contains
                                       the EPCRA section 313 chemical in percentages by
                                       weight of less than the following levels (These are
                                       known as de minimis levels)
                                         -   0.1 percent if the EPCRA section 313
                                            chemical is defined as an "OSHA
                                            carcinogen;"
                                             1 percent for other EPCRA section 313
                                            chemicals.
                                De minimis levels for each EPCRA section 313 chemical and
                                chemical category are listed in Table II.   PBT chemicals
                                (except lead when contained in stainless steel, brass or bronze
                                alloys)  are not eligible for the  de minimis  exemption.
                                Therefore, de  minimis levels are not provided for these
                                chemicals  in Table II.  However, for purposes  of supplier
                                notification requirements only, such notification is not required
                                when the following PBT chemicals are contained in mixtures
                                below their respective de minimis levels:
D-2
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                       Appendix D
Chemical or chemical
category name
Aldrin
Benzo[g,h,i]perylene
Chlordane
Dioxin and dioxin-like
compounds
(manufacturing; and the
processing or otherwise
use of dioxin and dioxin-
like compounds if the
dioxin and dioxin-like
compounds are present
as contaminants in a
chemical and if they
were created during the
manufacturing of that
chemical
Heptachlor
Hexachlorobenzene
Isodrin
Lead
Lead compounds
Mercury
Mercury compounds
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polychlorinated
biphenyls (PCBs)
Polycyclic aromatic
compounds category
Tetrabromobisphenol A
Toxaphene
CAS
number or
chemical
category
code
309-00-2
191-24-2
57-74-9
N150
76-44-8
118-74-1
465-73-6
7439-92-1
N420
7439-97-6
N458
72-43-5
29082-74-4
40087-42-1
608-93-5
1336-36-3
N590
79-94-7
8001-35-2
Supplier
notification
limit (%)
1.0
1.0
0.1
1.0*
0.1
0.1
1.0
0.1
o.r*
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1***
1.0
0.1

Chemical or chemical
category name
Trifluralin
CAS
number or
chemical
category
code
1582-09-8

Supplier
notification
limit (%)
1.0
                                   *The de minimis level is 1.0 for all members except for
                                   2,3,7,8-Tetrachlorodibenzo-p-dioxin which has a 0.1%
                                   de minimis level.
                                   **The de minimis level is 0.1 for inorganic lead
                                   compounds and 1.0 for organic lead compounds
                                   ***The de minimis level is 0.1 except for
                                   benzo(a)phenanthrene, dibenzo(a,e)fluoranthene,
                                   benzo(j,k)fluorene, and 3-methylcholanthrene which are
                                   subject to the 1.0% de minimis level.
                                          Your mixture or other trade name product is one of
                                          the following:
                                               An article that does not release an EPCRA
                                               section 313 chemical under normal
                                               conditions of processing or otherwise use.
                                               Foods, drugs, cosmetics, alcoholic
                                               beverages, tobacco, or tobacco products
                                               packaged for distribution to the general
                                               public.
                                               Any consumer product, as the term is defined
                                               in the Consumer Product Safety Act,
                                               packaged for distribution to the general
                                               public. For example, if you mix or package
                                               one-gallon cans of paint designed for use by
                                               the general public, notification is not
                                               required.
                                          A waste sent off site for further waste management.
                                          The supplier notification requirements apply only to
                                          mixtures  and trade name  products.  They do not
                                          apply to wastes.
                                          You are initiating distribution of a mixture or other
                                          trade name product containing one or more EPCRA
                                          section 313 chemicals and your facility is in any of
                                          the  covered SIC codes added  during the   1997
                                          industry expansion rulemaking, including facilities
                                          whose SIC code is within SIC major group codes 10
                                          (except 1011, 1081, and 1094),  12 (except 1241);
                                          industry codes 4911 (limited to facilities that combust
                                          coal and/or oil for the purpose of generating power
                                          for  distribution in commerce),  4931  (limited to
                                          facilities that combust coal and/or oil for the purpose
                                          of generating power for distribution in commerce), or
                                          493 9 (limited to facilities that combust coal and/or oil
                                          for the purpose of generating power for distribution
                                          in commerce); or 4953 (limited to facilities regulated
                                          under the Resource Conservation and Recovery Act,
Toxics Release Inventory Reporting Forms and Instructions
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                                                 Appendix D
        subtitle C, 42 U.S.C. Section 6921 et seq.) or 5169,        Information retained  under 40  CFR  372 must be readily
        or  5171, or 7389 (limited to facilities primarily        available for inspection by EPA.
        engaged in solvents recovery services on a contract
        or fee basis).


D.7  Trade Secrets

Chemical suppliers may consider the chemical name or the
specific concentration of anEPCRA section 313 chemical in a
mixture or other trade name product to be a trade secret.  If
they consider:

1.       The specific  identity of an EPCRA section 313
        chemical   to be a trade secret, the notice must
        contain a generic chemical name that is descriptive of
        the structure of that EPCRA Section  313 chemical
        (for example,  decabromodiphenyl oxide  could be
        described as a halogenated aromatic);
2.       The specific percentage by weight of an EPCRA
        section 313 chemical in the mixture  or other trade
        name product to be a trade secret, the notice must
        contain a  statement that the EPCRA section 313
        chemical is present at a concentration that does not
        exceed a specified upper bound.  For example, if a
        mixture contains 12 percent toluene and you consider
        the percentage a  trade secret, the notification may
        state that the mixture contains toluene at no more
        than 15 percent by weight. The upper bound value
        chosen must  be no  larger than  necessary  to
        adequately protect the trade secret.
If you claim this information to be trade secret, you must have
documentation that provides the basis for your claim.



D.8  Record keeping

Requirements

You are required to keep records of the following for three
years:

1.       Notifications sent to recipients of your mixture or
        other trade name product;
2.       All supporting materials  used to develop the notice;
3.       If claiming a specific EPCRA section 313 chemical
        identity a  trade secret, you should record why the
        EPCRA section 313 chemical identity is considered a
        trade secret and the appropriateness  of the generic
        chemical name provided in the notification; and
4.       If claiming a specific concentration a trade  secret,
        you should record explanations of why a specific
        concentration is considered a trade secret and the
        basis for the upper bound concentration limit.
D-4                       Toxics Release Inventory Reporting Forms and Instructions

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                                                Appendix D
D.9  Sample Notification  Letter
January 2, 2009

Mr. Edward Burke
Furniture Company of North Carolina
1000 Main Street
Anytown, North Carolina 99999

Dear Mr. Burke:
This letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-1390, contains one or more chemicals subject to
section 313 of Emergency Planning and Community Right-to-Know Act (EPCRA). We are required to notify you of the presence of
these chemicals in the product under EPCRA section 313. This law requires certain industrial facilities to report on annual emissions
and other waste management of specified EPCRA section 313 chemicals and chemical categories. Our product contains:


    •   Toluene, Chemical Abstract Service (CAS) number 108-88-3, 20 percent, and


    •   Zinc compounds, 15 percent.


If you are unsure whether you are subject to the reporting requirements of EPCRA section 313, or need more information, call the
EP A/TRI Information Center. For contact information, please see the TRI Home Page at http://www.epa.gov/tri. Your other suppliers
should also be notifying you about EPCRA section 313 chemicals in the mixtures and other trade name products they sell to you.

Finally, please note that if you repackage or otherwise redistribute this product to industrial customers,  a notice similar to this one
should be sent to those customers.


                                                        Sincerely,
                                                        Emma Sinclair
                                                        Sales Manager
                                                        Furniture Products
                          Toxics Release Inventory Reporting Forms and Instructions                 D-5

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                                        Appendix D
D.10  Sample  Notification  on an MSDS Furniture Products
      Section 313 Supplier Notification

      This product contains the following EPCRA section 313 chemicals subject to the reporting requirements of section 313
      of the Emergency Planning and Community Right-To-Know Act of 1986 (40 CFR 372):
      CAS Number      Chemical Name   Percent by Weight

      108-88-3          Toluene              20%
      NA             Zinc Compounds       15%

       This information must be included in all MSDSs that are copied and distributed for this material.
                                   Material Safety Data Sheet
D-6
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Appendix  E.     TRI  State Contacts	


EPCRA Section 313 requires facilities to submit reports to both EPA and their state. For a current list of
state designated Section 313 contacts, see the TRI web site at:

State TRI Contact Information and Web Sites: http://www.epa.gov/tri/stateprograms/statejrograms.htm
                 Toxics Release Inventory Reporting Forms and Instructions
E-l

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Appendix F.   TRI  Regional Contacts
Region 1 (CT, ME, MA, NH, RI, and VT)

   Dwight Peavey
   Assistance and Pollution Prevention Office
   USEPA Region 1 (SPT)
   1 Congress Street, Suite 1100
   Boston, MA 02114-2023
   (617) 918-1829; fax: (617) 918-1810
   peavey.dwight@epa.gov

Region 2 (NJ, NY, PR, and VI)

   Nora Lopez
   Pesticides and Toxic Substances Branch
   USEPA Region 2 (MS-105)
   2890 Woodbridge Avenue, Building 10
   Edison, NJ 08837-3679
   (732) 906-6890; fax: (732) 321-6788
   lopez.nora@epa.gov

Region 3 (DE, DC, MD, PA, VA, and WV)

   William Reilly
   Toxics Programs and Enforcement Branch
   USEPA Region 3 (3WC33)
   1650 Arch Street
   Philadelphia, PA 19103-2029
   (215) 814-2072; fax: (215) 814-3114
   reilly.william@epa.gov

Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)

   Ezequiel Velez
   EPCRA Enforcement Section
   USEPA Region 4
   Atlanta Federal Center
   6IForsyth Street, S.W.
   Atlanta, GA 30303-8960
   (404) 562-9191; fax: (404) 562-9163
   velez. ezequiel@epa. gov

Region 5 (IL, IN, MI, MN, OH, and WI)

   Thelma Codina
   Pesticides and Toxics Branch
   USEPA Region 5 (DT-8J)
   77 West Jackson Boulevard
   Chicago, IL 60604
   (312) 886-6219; fax: (312) 353-4788
   codina.thelma@epa. gov
Region 6 (AR, LA, NM, OK, and TX)

   Morton Wakeland
   Toxics Section, Multimedia Planning and Permitting
       Division
   USEPA Region 6 (6PD-T)
   1445 Ross Avenue, Suite 1200
   Dallas, TX 75202-2733
   (214) 665-8116; fax: (214) 665-6762
   wakeland.morton@epa.gov

Region 7 (IA, KS, MO, and NE)

   Stephen Wurtz
   Air, RCRA and Toxics Division
   USEPA Region 7 (ARTD/CRIB)
   901 North 5th Street
   Kansas City, KS  66101
   (913) 551-7315; fax: (913) 551-7065
   wurtz. stephen@epa. gov

Region 8 (CO, MT, ND, SD, UT, and WY)

   Barbara Conklin
   Office of Pollution Prevention, Pesticides and Toxics
   USEPA Region 8 (8P-P3T)
   1595 Winkoop Street
   Denver, CO 80202
   (303) 312-6619; Fax: (303) 312-6044
   Conklin.barbara@epa.gov

Region 9 (AS, AZ, CA, GU, HI, MH, MP, and
NV)

   Nancy Levin
   Toxics Office
   USEPA Region 9 (CED-4)
   75 Hawthorne Street
   San Francisco, CA 94105-3901
   (415) 972-3848; fax: (415) 947-3583
   levin.nancy@epa.gov

Region 10 (AK, ID, OR, and WA)

   Brook Madrone
   Office of Waste & Chemical Management
   USEPA Region 10 (AWT-128)
   1200 Sixth Avenue
   Suite 900
   Seattle, WA 98101-3140
   (206) 553-4016; Fax: (206) 553-8509
   Madrone.brook@epa.gov
                     Toxics Release Inventory Reporting Forms and Instructions
                                       F-l

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Appendix G.    Other Relevant Section  313  Materials
G.1   Public Data Release

2007 Toxics Release Inventory Public Data Release
Report

TRI data collected from 1987 through 2007 can be accessed
using the TRI Explorer online tool:

        http://www.epa.gov/triexplorer
as well as several other public access tools available on the
TRI  website.    In  addition,  users can  obtain summary
information and access the TRI data submitted for reporting
years 1996 through 2007 via the web from the TRI Public Data
Release            Internet           site           at
http://www.epa.gov/tri/tridata/index.htm.  This Internet site
provides fast and easy access to the TRI data submitted for
each of these years, as well as an overview of the data and
other relevant TRI information regarding each year (including
tables, charts, maps, and a summary of key findings). EPA has
released two electronic publications summarizing the 2007
data: the 2007 TRI Public Data Release  (PDR) Brochure
(EPA-260-R-09-001) and the 2007  Public  Data Release
eReport. These reports provide an overview of the 2007 TRI
reporting year data and other information relating to TRI data.
The reports serve as a supplement  to EPA's TRI Explorer
where, for example, users of TRI data can retrieve electronic
2007 state fact sheets that provide a snapshot of each state's
releases  and  other waste management  activities  and  a
description of the information included in the state fact sheet.
G.2  Access  to TRI

Information  On-line

The   TRI  Home   Page  http://www.epa.gov/tri  offers
information useful to both novice and experienced users of the
Toxics Release Inventory. It provides a description of what the
TRI database is and how it can be used; access to TRI data;
TRI regulations; and guidance documents for complying with
TRI regulations and using TRI data. You can find out about
TRI products, view or download the 2007 TRI data release
reports, and identify who to contact for more information in
EPA regions and state programs across the country. From the
TRI home page, you can link to other EPA and non-EPA sites
that also allow you to search the TRI database  and other
databases online.

TRI Explorer http://www.epa.gov/triexplorer is an on-line
tool that EPA has created to obtain TRI data.  It allows the
user to search the TRI database using six criteria: facility,
chemical, year or industry type (NAICS code), federal facility
and geographic area (at the county, state or national level).
The tool will generate three  types of reports: (1) Release
Reports  (including on- and off-site releases (i.e.,  off-site
releases include transfers off-site to disposal and metals and
metal compounds transferred to POTWs)); (2) Waste Transfer
Reports  (including amounts transferred off-site for further
waste  management but not including transfers off-site to
disposal); and (3) Waste Quantity Reports (including amounts
recycled, burned for energy recovery, quantities treated, and
quantities released).

TOXNET  http://toxnet.nlm.nih.gov the National Library of
Medicine's (NLM) Toxicology Data Network, provides free
access to several databases, including the TRI database, that
provides a variety of information on toxic chemicals. As with
EPA's TRI Explorer tool, users of TOXNET can search by
chemical or other name, chemical name fragment, or Chemical
Abstracts Service Registry Number.  Also searchable are
facility or parent company name, state, city, county, or zip
code.  Search results can be limited to releases greater than a
specified number of pounds, and individual releases can be
summed together to display a total amount.  Toxicity and
environmental fate data for thousands of chemicals are also
available from TOXNET.
G.3  Other  TRI  Information

EPA's  Integrated  Risk Information  System  (IRIS)
http://www.epa.gov/iris is an electronic database containing
information on human health effects that may result from
exposure to various chemicals, including TRI chemicals, in the
environment. IRIS was initially developed for EPA staff in
response to a growing demand for consistent information of
chemical substances for use in risk assessments, decision-
making and regulatory activities.  The information in IRIS is
intended for those without extensive training in toxicology, but
with some knowledge of health sciences.

Consolidated List of Chemicals Subject to the Emergency
Planning and Community Right-to-Know Act and Section
112(r) of the Clean Air Act (List of Lists), (October 2001):

        http://www.epa.gov/ceppo/pubs/title3.pdf
A  paper copy  is  available from the National  Technical
Information Service, 5285 Port Royal Road, Springfield, VA
22161, 703 605-6000, Document Number: PB2003-105834,
$38.00 plus $5.00 shipping and handling.

Chemicals in Your Community, A Citizen's Guide to the
Emergency Planning and Community Right-to-Know Act,
December 1999 (EPA 550-99-001).

This booklet is intended to provide a general overview of the
EPCRA requirements and benefits for all audiences. Part I of
the booklet describes the provisions of EPCRA and Part II
describes more fully  the authorities  and responsibilities of
groups of people affected by the law and is available through
                               Toxics Releases Inventory Forms and Instructions
                                               G-l

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                                                  Appendix G
written request at no charge from the EPA/TRI Information
Center.  For contact information, please see the TRI Home
Page at http://www.epa.gov/tri.

Chemicals in the Environment

Issue  number 6 of Chemicals in the  Environment (CIE),
published in the Fall of 1997, is devoted entirely to TRI.  This
22 page publication contains 19 articles ranging from the
history of TRI  to the future of new TRI products.  Articles
include perspectives from the community, state, Federal, and
International level.  The publication also provides valuable
information on training and contacts within the EPA. CIE is
available free from EPA by asking for publication EPA 749-R-
97- 00Ib. To request copies, contact:

    U.S. Environmental Protection Agency
    Ariel Rios  Building
    1200 Pennsylvania Ave., N.W.
    Attn: TRI  Documents
    MC: 2844
    Washington, DC 20460

    202 564-9554
    Email:  TRIDOCS@epa.gov

The  Pollution Prevention  Information  Clearinghouse
(PPIC) http://www.epa.gov/oppt/ppic/index.html

PPIC  was established as part of EPA's response to the
Pollution Prevention Act of 1990, which directed the Agency
to compile information, including a database, on management,
technical, and  operational approaches  to source  reduction.
PPIC  provides information to the  public  and  industries
involved in conservation of natural resources and in reduction
or elimination  of pollutants in facilities, workplaces, and
communities.

To request EPA information on pollution prevention or obtain
fact sheets on pollution prevention from various state programs
call the PPIC reference and referral service at 202 566-0799,
or fax a request to 202 566-0794, or write to:

    U.S. EPA
    Pollution Prevention Information Clearinghouse (PPIC)
    EPA West
    1200 Pennsylvania Ave. NW
    Room 3379 (Mail Code 7407-T)
    Washington, DC 20460-0001

    Email:  ppic@epa.gov
G-2                             Toxics Releases Inventory Forms and Instructions

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Appendix  H.    Guidance Documents	


H.1  General  Guidance

Many of the TRI guidance documents are available via the Internet http://www.epa.gov/tri.

   •  40 CFR 372, Toxic Chemical Release Reporting; Community Right-to-Know; Final Rule
      A reprint of the final EPCRA section 313 rule as it appeared in the Federal Register (FR) February 16, 1988 (53
      FR 4500) (OTSFR 021688).

   •  Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and Community
      Right-to-Know Act
      March 1995 (EPA 745R-95-008)

      This glossary contains chemical names and their synonyms for substances covered by the reporting requirements
      of EPCRA section 313.  The glossary was developed to aid in determining whether a facility manufactures,
      processes, or otherwise uses a chemical subject to EPCRA section 313 reporting.

   •  EPCRA Section 313 Questions and Answers - Revised 1998 Version
      December 1998 (EPA 745-B-98-004)

      The revised 1998 EPCRA Section 313 Questions and Answers document assists regulated facilities in complying
      with the reporting requirements of EPCRA section 313. This updated document presents interpretive guidance
      in the  form of answers to many commonly asked  questions on compliance with EPCRA section 313.  In
      addition, this document includes comprehensive written directives to assist covered facilities in understanding
      some of the more complicated regulatory issues. This updated guidance document is intended to supplement the
      instructions for completing the Form R and the Alternate Threshold Certification Statement (Form A).

   •  EPCRA Section 313 Questions and Answers - Addendum to the Revised 1998 Version
      December 2004 (EPA-260-B-04-002)

      As a result of Executive Order 13148, regulatory actions, and legal decisions over the past five years, some of
      the Qs & As contained in the 1998 Q &A Document were updated. The 1998 Q & A Document remains valid
      guidance in all other respects.

   •  EPCRA Section 313 Questions and Answers Addendum for Federal Facilities
      May 2000 (EPA 745-R-00-003)

      This document is an addendum to the EPCRA section 313 Questions and Answers: Revised 1998 Version.  It
      provides additional assistance to federal facilities in complying with EPCRA section 313. Federal facilities,
      which are subject to compliance under EPCRA through Executive Order 13423, frequently have operations that
      are different from the private sector facilities subject to EPCRA.  The document contains questions and answers
      that address some of those differences.

   •  EPCRA Section 313 Release and Other Waste Management Reporting Requirements
      February 2001 (EPA260/K-01-001)

      The brochure  alerts businesses to their  reporting obligations under  EPCRA section  313  and assists in
      determining whether their facility is  required to report. The brochure contains the EPA regional contacts, the list
      of EPCRA section 313 toxic chemicals and a description of the Standard Industrial Classification (SIC) codes
      subject to EPCRA section 313.

   •  Toxic Chemical Release Reporting Using 2007 North American Industry Classification System (NAICS)
      Final Rule (73 FR 32466; June 9,  2008): This final rule incorporates 2007 Office of Management and Budget
      (OMB) revisions and other corrections to the NAICS codes used for TRI Reporting.
                      Toxics Release Inventory Reporting Forms and Instructions              H-1

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                                          Appendix H
   •  Toxic Chemical Release Reporting Using North American Industry Classification System (NAICS) Final
      Rule (71 FR 32464; June 6,2006): With this rulemaking, Toxics Release Inventory (TRI) reporting will require
      North American Industry Classification System (NAICS) codes in place of Standard Industrial Classification
      (SIC) codes. North American Industry Classification System (NAICS), United States, 2002, Executive Office of
      the President, Office of Management and Budget, NTIS Order Number: PB2002-101430
   •  Persistent Bioaccumulative Toxic (PBT) Chemicals; Final Rule (64 FR 58666)
      A reprint of the final rule that appeared in the Federal Register of October 29, 1999. This rule adds certain PBT
      chemicals and chemical categories for reporting year 2000 and beyond under EPCRA section 313, lowers their
      activity thresholds and modifies certain reporting exemptions and requirements for PBT chemicals and chemical
      categories. In a separate action, as part of the October 29, 1999 rulemaking, EPA added vanadium (except when
      contained in alloy) and vanadium compounds. These are not listed as PBT chemicals.


H.2 Supplier Notification  Requirements

(EPA 560-4-91-006)

This pamphlet assists chemical suppliers who may be subject to the supplier notification requirements, gives examples
of situations which require notification, describes the trade secret provision, and contains a sample notification.

   •  Toxic Chemical Release Inventory Reporting Forms and Instructions Revised 2006 Version
      February 2007 (EPA 260-C-06-901)

   •  Toxics Release Inventory: Reporting Modifications Beginning with 1995 Reporting Year
      February 1995 (EPA 745-R-95-009)

   •  Trade Secrets Rule and Substantiation Form
   •  (53 FR 28772)
      A reprint of the final rule that appeared in the Federal Register of July 29, 1988. This rule implements the trade
      secrets provision of the Emergency Planning and Community Right-to-Know Act (section 322).  The current
      trade secret substantiation form can be accessed at http://www.epa.gov/tri/report/index.htarfforms


H.3 Chemical-Specific Guidance

EPA has developed a group of guidance documents specific to individual chemicals and chemical categories.

   •  Emergency Planning and Community Right-to-Know Section 313:  List of Toxic Chemicals within the
      Chlorophenols Category
      June 1999 (EPA745-B-99-013)

   •  Toxics Release Inventory List of Toxic  Chemicals within the Glycol Ethers Category and Guidance for
      Reporting
      December 2000 (EPA745-R-00-004)

   •  Emergency Planning and  Community  Right-to-Know  Act  Section 313: Guidance  for  Reporting
      Hydrochloric Acid (acid aerosols including mists, vapors, gas, fog and  other airborne forms  of any
      particle size)
      December 1999 (EPA 745-B-99-014)

   •  Emergency Planning and Community Right-to-Know Act - Section 313:  Guidance for Reporting Releases
      and Other Waste Management Activities of Toxic Chemicals: Lead and Lead Compounds
      November 2001 (EPA-260-B-01-027)

   •  Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
      Chemicals: Mercury and Mercury Compounds Category
      August 2001 (EPA260-B-01-004)


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                                          Appendix H
   •  Toxics Release Inventory List of Toxic Chemicals within the Nicotine and Salt Category and Guidance for
      Reporting
      June 1999 (EPA745-R-99-010)

   •  Toxics Release Inventory List of Toxic Chemicals within the Water Dissociable Nitrate Compounds
      Category and Guidance for Reporting
      December 2000 (EPA 745-R-00-006)

   •  Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
      Chemicals: Pesticides and Other Persistent Bioaccumulative Toxic (PBT) Chemicals
      August 2001 (EPA260-B-01-005)

   •  Toxics Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes  Category  and
      Guidance for Reporting
      June 1999 (EPA745-B-99-023)

   •  Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
      Chemicals: Polycyclic Aromatic Compounds Category
      August 2001 (EPA260-B-01-003)

   •  Toxics Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and Guidance
      for Reporting
      June 1999 (EPA745-R-99-011)

   •  Emergency Planning and Community Right-to-Know Act Section 313: Guidance for Reporting Sulfuric
      Acid (acid aerosols including mists, vapors, gas, fog and other airborne forms of any particle size)
      March 1998 (EPA745-R-97-007)

   •  Toxics Release Inventory List of Toxic Chemicals within Warfarin Category
      June 1999 (EPA745-B-99-011)

   •  Toxics Release Inventory List of Toxic Chemicals within  Ethylenebisdithiocarbamic Acid,  Salts  and
      Esters Category and List of Mixtures that Contain the Individually listed Chemicals Maneb, Metiram,
      Nabam, and Zineb
      September 2001 (EPA260-B-01-026)

   •  Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Aqueous
      Ammonia
      December 2000 (EPA 745-R-00-005)

   •  Emergency Planning and Community Right-to-Know Act - Section 313: Guidance for Reporting Toxic
      Chemicals within the Dioxin and Dioxin-like Compounds Category
      December 2000 (EPA 745-B-00-021)

H.4 Industry-Specific  Guidance
EPA has developed specific guidance documents for certain industries.

   •  EPCRA Section 313: Guidance for Chemical Distribution Facilities
      January 1999 (EPA 745-B-99-005)

   •  EPCRA Section 313: Guidance for Petroleum Terminals and Bulk Storage Facilities
      February 2000 (EPA 745-B-00-002)

   •  EPCRA Section 313: Guidance for Coal  Mining Facilities
      February 2000 (EPA 745-B-00-003)


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                                           Appendix H
   •  EPCRA Section 313: Guidance for Electricity Generating Facilities
      February 2000 (EPA 745-B-00-004)

   •  EPCRA Section 313 Reporting Guidance for Food Processors
      September 1998 (EPA 745-R-98-011)

   •  EPCRA Section 313 Reporting Guidance for the Leather Tanning and Finishing Industry
      April 2000 (EPA 745-B-00-012)

   •  EPCRA Section 313: Guidance for Metal Mining Facilities
      Januaryl999 (EPA 745-B-99-001)

   •  Emergency  Planning  and Community  Right-to-Know Act Section 313  Reporting  Guidance for the
      Presswood and Laminated Products Industry
      August 2001 (EPA260-B-01-013)

   •  EPCRA Section 313 Reporting Guidance for the Printing, Publishing, and Packaging Industry
      May 2000 (EPA 745-B-00-005)

   •  EPCRA Section 313: Guidance for RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities
      January 1999 (EPA 745-B-99-004)

   •  EPCRA Section 313 Reporting Guidance for Rubber and Plastics Manufacturing
      May 2000 (EPA 745-B-00-017)

   •  EPCRA Section 313 Reporting Guidance for Semiconductor Manufacturing
      July 1999 (EPA745-R-99-007)

   •  EPCRA Section 313 Reporting Guidance for the Textile Processing Industry
      May 2000 (EPA 745-B-00-008)

   •  EPCRA Section  313  Reporting  Guidance for Spray Application  and Electrodeposition of Organic
      Coatings
      December 1998 (EPA 745-R-98-014)
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Appendix  I.    Questions and Answers  Regarding
Facility Identification  Information
1.1    Categories
This document provides additional information about TRI
reporting procedures based on some frequently asked
questions.  The questions and their answers are organized
into three groups:

Section 1.2  Identifying the parent company.
Section 1.3  Reporting after a change in name or
          ownership.
Section 1.4  Reporting for multiple sites and/or owners.
1.2   Identifying the Parent

Company

A. Question
When a facility changes ownership after a Form R has been
submitted, who is required to respond to a Notice of
Noncompliance (NON) related to the Form R? Is the
current or prior owner/operator required to respond to the
NON?

A. Answer
The current owner/operator has the primary responsibility
for responding to a NON. However, all prior
owners/operators back to January 1 of the reporting year
may also be held responsible if the current owner/operator
does not respond to the NON in an accurate, complete, and
timely manner.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question 31 (EPA 745-B-97-008)).
B. Question
Who is the parent company for a 50/50 joint venture?

B. Answer
The 50/50 joint venture is its own parent company.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #33 (EPA745-B-97-008)).
C. Answer
Big Oil Corporation is the parent company.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #35 (EPA 745-B-97-008)).


1.3    Reporting After a

Change  in  Name or

Ownership

A. Question
The owner/operator of a covered facility is preparing Form
Rs for a facility. The facility and its parent company both
changed their names after the reporting year. What names
should be reported by the owner/operator (for both the
facility and the parent company) on the Form Rs covering
the reporting year?

A. Answer
The facility should report the names used by the facility and
parent company during that reporting year. When the
owner/operator submits Form Rs for the next reporting year,
these  reports should reflect the names used by the facility
and parent company during the new reporting year.  Note
that the TRI facility identification number will not change.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #457 (EPA 745-B-97-008)).
B. Question
If a covered facility does not have a Dun & Bradstreet
(D&B) number but the parent corporation does, should this
number be reported?

B. Answer
Report the D&B number for the facility. If a facility does
not have a D&B number, enter "NA" in Part I, Section 4.7.
The corporate D&B number should be entered in Part I,
Section 5.2 relating to parent company information.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #464 (EPA 745-B-97-008)).
C. Question
Mom and Pop Plastics is a wholly owned subsidiary of a
major chemical company which is a wholly owned
subsidiary of Big Oil Corporation, located in St. Paul,
Minnesota. Which is the parent company?
C. Question
In October 2009, Facility X changes ownership and is
purchased by Company Y. For the 2009 reporting year,
which facility is obligated to submit the Form R or Form A,
and whose name and what TRI identification number should
be on the form?

C. Answer
The owner or operator of the facility on the annual July 1
reporting deadline (i.e., Company Y) is primarily
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                                                  Appendix I
responsible for reporting the data for the entire previous
year's operations at that facility. Any other owner or
operator of the facility before the reporting deadline may
also be held liable. The form submitted for a given reporting
year must reflect the names used by the facility and its
parent company on December 31 of that reporting year,
even if the facility  changed its name or ownership at any
time during the reporting year.  In this scenario, because
Facility X changed ownership before December 31 of the
reporting year, Company Y's name should appear on the
form. The TRI identification number is location-specific;
thus, the identification number will stay the same even if the
facility changes names, production processes, or NAICS
codes.
(Source: Monthly Call Center Report Question EPA530-R-
98—5j; October 1998).
1.4    Reporting for  Multiple

Sites  and/or  Owners
A. Question
If two plants are separate establishments under the same site
management, must they have separate D&B numbers?

A. Answer
They may have separate D&B numbers, especially if they
are distinctly separate business units. However, different
divisions of a company located at the same facility usually
do not have separate D&B numbers.
(Source: 1997 EPCRA Section 313 Questions and Answers
Document, Question #465 (EPA745-B-97-008)).
B. Question
An electricity generating facility (EOF) is comprised of
multiple independent owners. Each individual owner runs
his/her own separate operation, but each has a financial
interest in the operation of the entire facility. What name
should be entered as the parent company in Part I, Section
5.1 of the Form R?  Should the facility report under one
holding company name?

B. Answer
The EGF should enter in Part I, Section 5.1 of the Form R
the name of the holding or parent company, consortium,
joint venture, or other entity that owns, operates, or controls
the facility.
(Source: Question #2, Addendum to the Guidance
Documents for the Newly Added Industries (EPA 745-B-
98-001)).
C. Question
A covered facility sells one of its establishments to a new
owner. The operator of the newly sold establishment,
                                however, does not change. The same operator operates the
                                newly sold establishment and the rest of the facility.
                                Although the facility makes its threshold determinations
                                based on the activities at the entire facility (including the
                                newly sold establishment), the facility chooses to report
                                separately for the different establishments. What parent
                                name should the newly sold establishment use, the parent
                                name of the owner or the parent name of the operator (i.e.,
                                the same as the rest of the facility)?

                                C. Answer
                                All establishments of a covered facility must report the
                                parent name of the facility. Therefore, in the instance
                                described above, the newly sold establishment should use
                                the parent name of the facility operator (i.e., the same parent
                                name the rest of the facility is using).
                                (Source: Spring Training 1998).
                                D. Question
                                Company A purchases a facility from Company B between
                                January 1, 2006 and June 30, 2006. For the 2005 reporting
                                year, which company's name and identification number
                                should appear on the Form R or Form A submission?

                                D. Answer
                                In the case that a facility is purchased between January 1
                                and June 30, the form submitted for the previous year must
                                reflect the name used by the facility on December 31 of that
                                reporting year. In this example, company B's name should
                                appear on the form because it owned the facility for the
                                duration of the reporting year. The TRI identification
                                number is location-specific; thus, the identification number
                                will stay the same even if the facility changes names,
                                production processes, or NAICS codes.

                                With regard to reporting, the owner or operator of the
                                facility on the annual July 1 reporting deadline (Company
                                A) is primarily responsible for reporting the data for the
                                previous year's operations at that facility. However, all prior
                                owners and  operators back to January 1 of the year covered
                                in the report may also be held responsible if the current
                                owner or operator does not submit a report.
                                (Source: Monthly Call Center Report Question EPA530-R-
                                98—5j; October 1998)
                                E. Question
                                Two distinct NAICS code operations that are covered under
                                EPCRA Section 313 (e.g., an electricity generating unit and
                                a cement plant) are located on adjacent properties and are
                                owned by the same parent company. The two operations are
                                operated completely independently of one another (e.g.,
                                separate accounting procedures, employees, etc.). Are these
                                two operations considered one facility under EPCRA
                                Section 313?
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                                                    Appendix I
E. Answer
Yes. Under EPCRA Section 313, a facility is defined as, "all
buildings, equipment, structures, and other stationary items
which are located on a single site or on contiguous or
adjacent sites and which are owned or operated by the same
person." Because these two operations are located on
adjacent properties and are owned by the same person they
are considered one facility for EPCRA Section 313
reporting purposes. Additional information can be found in
the 2009 Toxic Release Inventory Reporting Forms and
Instructions.
F. Question
A piece of contiguous property consists of three covered
sites with various buildings, structures and equipment. The
three sites are owned by two different companies -
Company A and Company B. All three sites operate
completely independently of each other and have separate
personnel, finances, and environmental reporting systems.
Site  1 and its buildings and structures are owned and
operated by Company A and site 3 and its buildings and
structures are owned and operated by Company B. The
middle site, site 2 and its surrounding buildings and
structures, are owned by Company A and operated by
Company B. Are all three sites and their buildings and
structures considered separate facilities under EPCRA
Section 313? Who is responsible for reporting for each?

F. Answer
Under 40 CFR Section 372.3 a facility is defined as "all
buildings, equipment, structures, and other stationary items
which are located on a single site or on contiguous or
adjacent sites and which are owned or operated by the same
person."  Because all buildings and structures located on
sites 1 and 2 are located on contiguous property and are
owned by the same person, they are considered one facility.
Because all buildings and structures located on sites 2 and 3
are located on contiguous property and are operated by the
same person, they are also considered one facility.
Therefore, for purposes of determining thresholds, the toxic
chemicals manufactured, processed, and otherwise used at
site 2 must  be counted toward both Facility A's and Facility
B's threshold determinations. Because the operator is
primarily responsible for reporting, estimating and reporting
releases and other waste management calculations for sites 2
and 3 are the primary responsibility of Company B,  and the
release and other waste management reporting for site 1 is
the primary responsibility of Company A. EPA allows the
release and other waste management reporting to be done in
this manner to avoid "double counting" releases and waste
management activities at site 2. However, provided
thresholds have been exceeded, if no reports are received
from a covered facility, determinations can be found in the
2009 Toxic Release Inventory Reporting Forms and
Instructions.
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